Risk and Control Measures for Bank-Crypto Engagement
Guide
As digital asset usage and value continue to penetrate the financial ecosystem, the decision of whether — and how — banks engage with the cryptocurrency industry is becoming increasingly common. From offering custodial services and trading platforms to banking crypto firms, financial institutions are shouldering an evolving burden to navigate a complex regulatory environment, a rapidly shifting technological landscape, and a dynamic risk environment. This guide seeks to provide a comprehensive overview of the key risks, regulatory developments, and strategic considerations for banks exploring crypto integration. It also aims to offer practical insights and control frameworks designed to support sound decision-making and robust risk management in this high-stakes domain.

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Author Bio
David Lutz, CAMS, CCI, CCA, MBA Associate Director, Financial Crimes Advisory
David Lutz, is a financial crime compliance leader with over 16 years of experience in BSA/AML, sanctions, fraud, and crypto investigations. He began his career in 2008 conducting independent BSA/AML and OFAC reviews for banks and fintechs, and later transitioned into enterprise banking audit, leading FCC and technology-focused reviews, including cloud migration oversight.
In 2020, David expanded his career into cryptocurrency investigations, helping victims of crypto fraud—including romance scams (pig butchering schemes), Defi rug pulls, fraudulent investment opportunity scams, and Ransomware investigations. Using a range of blockchain analytics tools, he has traced illicit transactions, followed the money across decentralized ecosystems, and supported referrals to law enforcement. An Associate Director on our Financial Crimes Advisory team, he helps advise banks and fintechs entering the digital asset space, helping them design effective risk frameworks, monitoring systems, and regulatory compliance programs.
David holds a CAMS certification, an MBA, Certified Cryptocurrency Auditor and Certified Cryptocurrency Investigator designation, combining traditional financial expertise with modern investigative techniques to help institutions stay ahead of emerging threats.
