Anti-Money Laundering for Crowdfunding & Digital Asset Platforms (AML/CFT/CPF)
Crowdfunding and digital asset platforms are reporting institutions under the SC's Guidelines on Prevention of Money Laundering, Countering Financing of Terrorism, Countering Proliferation Financing and Targeted Financial Sanctions, revised on 13 June 2024. Their exposure looks nothing like a bank's or a law firm's. Every investor is onboarded remotely, often thousands in a single campaign. Money flows toward issuers and borrowers the platform has vetted but does not control, and on P2P platforms it flows back again as repayments. Shares change hands on a secondary market between people who have never met, and on digital asset platforms value moves between wallets the platform can only see through analytics.
This course covers only what is specific to that model. It does not repeat the AML basics, the Compliance Officer's core duties or STR mechanics, which are taught in AML/CFT Compliance Officer Essentials and AML/CFT Compliance Officer Advanced. Participants should have that grounding, or equivalent experience, before attending. Front-line staff who need awareness only should attend AML/CFT Staff Awareness instead.
HRD Corp SBL-Khas Claimable
Programme Agenda
Day 1, 9:00 AM - 9:15 AM
Welcome and Programme Overview
Introduction to the session, objectives, and housekeeping.
Day 1, 9:15 AM - 10:15 AM
The SC AML/CFT/CPF Framework for Platform Operators
How the June 2024 SC guidelines apply to Recognized Market Operators and digital asset businesses specifically, what changed from the previous version, including board and senior management accountability, National Risk Assessment findings, proliferation financing and the dedicated digital asset requirements. Where platform obligations differ from those of a broker or fund manager.
Day 1, 10:15 AM - 10:30 AM
Break
Day 1, 10:30 AM - 12:30 PM
Platform Business Risk Assessment
Building a risk assessment for a two-sided marketplace: investor risk, issuer risk, product risk across equity, notes and tokens, channel risk for fully remote onboarding, and geographic risk from foreign investors and offshore wallets. Workshop: draft the risk matrix for a platform running ECF, secondary trading and a token offering.
Day 1, 12:30 PM - 1:30 PM
Lunch
Day 1, 1:30 PM - 3:15 PM
Remote Onboarding and Investor Due Diligence at Scale
eKYC, liveness and document checks, and where they fail. Proportionate due diligence when a campaign brings in thousands of small investors in days. Source of funds against declared income and investment limits, PEPs among investors, and detecting multiple accounts controlled by one person to break investment limits.
Day 1, 3:15 PM - 3:30 PM
Break
Day 1, 3:30 PM - 4:45 PM
Issuer and Borrower Due Diligence, Use of Proceeds and Repayments
Money laundering risk on the fundraising side: beneficial owners of the issuer or borrower, nominee shareholders, founders as PEPs, related-party investors who are really the issuer's own money coming back, misuse of raised funds, and on P2P platforms, early repayments from unexplained third parties and loan cycling used to clean money. Integrating AML checks into the issuer onboarding decision rather than bolting them on.
Day 1, 4:45 PM - 5:00 PM
Day 1 Close
Recap and what to review before day two.
Day 2, 9:00 AM - 9:15 AM
Day 1 Review
Recap of day one and the questions it left open.
Day 2, 9:15 AM - 10:15 AM
Secondary Market and Transaction Monitoring
Red flags specific to ECF secondary trading, P2P note activity and digital asset trading: circular trades between connected accounts, prices out of line with fundamentals, rapid deposit and withdrawal, and layering through small repeated trades. Designing monitoring rules that fit platform volumes, tuning alerts and documenting dispositions.
Day 2, 10:15 AM - 10:30 AM
Break
Day 2, 10:30 AM - 12:30 PM
Digital Assets: Wallet Screening, Blockchain Analytics and the Travel Rule
Screening deposit and withdrawal addresses, using blockchain analytics and understanding their limits, exposure to mixers, darknet markets and sanctioned addresses, and self-hosted wallets. The Travel Rule obligations in force since April 2022: what originator and beneficiary information must travel with a transfer, and handling counterparties that cannot comply.
Day 2, 12:30 PM - 1:30 PM
Lunch
Day 2, 1:30 PM - 3:15 PM
Targeted Financial Sanctions and Proliferation Financing on a Platform
Screening investors, issuers, directors and wallet addresses against domestic and UN lists, freezing and reporting obligations, and proliferation financing typologies involving digital assets. Handling true matches, false positives and screening at onboarding against ongoing screening.
Day 2, 3:15 PM - 3:30 PM
Break
Day 2, 3:30 PM - 4:45 PM
Case Workshop and Supervisory Readiness
End-to-end cases drawn from platform typologies: a suspicious campaign, a P2P borrower repaid by an unrelated party, a secondary market ring, and a token withdrawal to a high-risk wallet. For each, the decision, the report and the records. What SC supervisors examine at a platform, and a 90-day improvement plan for your own programme.
Day 2, 4:45 PM - 5:00 PM
Wrap-Up and Q&A
Key takeaways, next steps, and close.
Key Outcomes
- Apply the June 2024 SC AML/CFT/CPF/TFS Guidelines to a crowdfunding or digital asset platform
- Build a platform business risk assessment covering investors, issuers, products and channels
- Design proportionate remote onboarding and investor due diligence for high-volume campaigns
- Integrate AML checks into issuer and borrower due diligence and monitor use of proceeds and repayments
- Monitor secondary market and digital asset activity with platform-specific red flags
- Operate wallet screening and meet Travel Rule obligations for digital asset transfers
- Screen investors, issuers and wallets for targeted financial sanctions and proliferation financing
Training Mode Physical / Online / Hybrid / e-learning
HRD Corp SBL-Khas Claimable
Level Intermediate. For compliance officers, MLROs, onboarding and operations leads at SC-registered platforms. Assumes AML Compliance Officer grounding: attend AML/CFT Compliance Officer Essentials first if new to the role.
Duration 2 Days (16 Hours) | 9:00 AM to 5:00 PM daily
Venue In-house at the client's premises, or delivered via the client's preferred platform (Microsoft Teams, Zoom, or equivalent)
Assessment Three platform case studies with written decisions and reporting rationale, and a written knowledge check
Certificate Certificate of Completion issued to all participants upon full attendance