KYC programme review
Identity verification methodology, document and liveness checks, and risk tiering for a remote, high-volume customer base.
A stablecoin or digital asset platform's compliance stack is only as strong as its weakest layer. We review the layers your AML/CFT and Travel Rule programme does not reach on its own: identity and business verification, on-chain monitoring, wallet security governance, fraud risk scoring and case management, then tell you where it would not hold up to a regulator or an auditor.
An independent review of the identity verification, business verification, on-chain monitoring, wallet security governance, fraud risk scoring and case management controls around a stablecoin or digital asset platform's payments.
AML/CFT and Travel Rule obligations get most of the attention because they are explicit regulatory requirements, and platforms build programmes to meet them. The controls around who is actually being onboarded, what a wallet's risk score is really based on, who can move funds and how an alert becomes a filed report get far less scrutiny, and are usually where a platform's real exposure sits.
Identity verification methodology, document and liveness checks, and risk tiering for a remote, high-volume customer base.
Business customer verification, registry checks and whether ownership is traced to the natural person who controls it.
Wallet and address risk scoring as a standing control, tool configuration and alert triage, separate from Travel Rule messaging.
Custody model, key management oversight, multisig and approval thresholds, and transaction limits and exceptions.
Model governance for account takeover, synthetic identity and transaction anomaly detection, and how thresholds are set and revisited.
Case workflow, investigation documentation, STR/SAR filing triggers and the audit trail a case management process produces.
Scoped to the controls around onboarding, monitoring, custody and case handling, not just the AML framework.
Findings are built on walkthroughs and sample testing, not a policy read-through.
We do not sell or implement screening, analytics or custody tools, so the recommendation is what the programme needs.
A summary that gives directors a real position, not a clean bill of health by default.
Findings cross-referenced against your existing AML/CFT, Travel Rule and sanctions screening controls.
Platform model, customer base and systems in use.
Tracing onboarding, monitoring, custody and case handling end to end.
Sample onboarding files, wallet screening decisions, case files and model thresholds.
Findings ranked by exposure, not by framework section.
Findings, remediation plan and a board summary.
Findings ranked by exposure, with evidence.
Sample onboarding and verification files reviewed.
Tool configuration, alert handling and custody governance.
Model governance and case file quality.
Owners, actions and a position statement for directors.
We do not resell products, so nothing here is shaped by a vendor margin. The recommendation is whatever your risk and your budget actually justify, including telling you that you do not need the engagement yet.
Findings come with a sequence, an owner and a realistic effort estimate, sized to the team you have rather than the team a framework assumes. A report that cannot be acted on is an expense, not a control.
Our people have carried the obligation internally, not only audited it. That shows up in what we consider proportionate, and in how much documentation we think you genuinely need.
Work is grounded in Malaysian law and regulator expectation, from the PDPA and the Cyber Security Act 2024 to Bursa, BNM and SC requirements, rather than translated from a European or American template.
Where an engagement includes training, the training component is structured to be HRD Corp SBL-Khas claimable, which changes what the programme costs you in practice.
That review tests your AML/CFT programme and Travel Rule compliance directly. This review covers the layers around it: identity and business verification methodology, on-chain monitoring, wallet security governance, fraud scoring and case management.
We review how they are configured, used and governed, and sample test outcomes. We do not sell or implement the systems themselves.
Exchanges, stablecoin issuers, payment or e-money platforms handling digital assets, and crowdfunding platforms running token offerings.
Yes. The review is scoped to your platform, and a single layer can be reviewed on its own.
At least annually, and after a material change to onboarding, custody arrangements or risk-scoring models.