Practice Area

Crypto AML & BSA Compliance Audits

Comprehensive crypto AML compliance audits — Bank Secrecy Act programs, KYC and transaction monitoring, and the documentation that keeps regulators and banking partners satisfied. Conducted in English and Spanish.

Most crypto and payments companies fall within the Bank Secrecy Act as money services businesses, which means a written AML program, FinCEN registration, and a set of controls a banking partner can actually rely on — not a policy template no one follows. The Anti-Money Laundering Act of 2020 only sharpened those expectations for virtual asset businesses.

I conduct full crypto AML and Bank Secrecy Act compliance audits: I review your program, interview the people who run it, test whether the controls actually work against how financial crime really moves, and produce the documentation that regulators, banks, and counterparties want to see. When your team operates in Spanish, I conduct the interviews and write the deliverables in Spanish too.

Who needs an AML compliance audit

  • Crypto exchanges and VASPs subject to AML regulations and transaction monitoring obligations
  • Payments companies and processors expanding into Latin America
  • Fintechs preparing for a regulatory examination, bank onboarding, or investor due diligence
  • Companies that received questions from a bank or regulator about their AML program

What the audit covers

  • Full Bank Secrecy Act / AML program review against current regulations
  • KYC, customer due diligence, and sanctions-screening assessment
  • Transaction monitoring and suspicious activity reporting (SAR) controls
  • Cybersecurity and SOC 2 posture relevant to financial-crime risk
  • Bilingual (English/Spanish) team interviews and written findings

What a crypto AML compliance audit looks for

A BSA program rests on four pillars: a designated compliance officer, written internal policies and controls, ongoing training, and independent testing. An audit tests whether those pillars exist on paper and whether they function in practice — which are not the same thing. The failures I see are rarely about intent. They are monitoring thresholds set once when a vendor tool was installed and never tuned, sanctions screening that runs against names but not wallet addresses, and customer due diligence that never captures beneficial ownership for legal-entity customers as the FinCEN CDD rule requires.

I assess the program end to end against how financial crime actually moves: governance and the compliance officer's authority, KYC and customer due diligence, OFAC sanctions and PEP screening, transaction monitoring calibrated to your real flows, suspicious activity report decisioning, currency transaction and recordkeeping obligations, the funds-transfer travel rule, and training. The goal is a program that is both defensible and operationally realistic for a company that is still growing.

Why banks and regulators care about your program

When a bank onboards a crypto company, it inherits that company's financial-crime risk and answers for it to its own examiners. That is why a thin AML program is one of the fastest ways to be de-risked off a bank's books — and why regaining access afterward is far harder than keeping it. A credible, documented audit is frequently what keeps the relationship, or wins it back.

The same file does double duty in investor and partner diligence. A clean audit record signals operational maturity and removes a recurring objection during fundraising and commercial negotiations, where a missing AML program is a standard reason a deal stalls.

Bilingual audits across the Americas

Many payments and fintech teams building stablecoin rails in Latin America operate primarily in Spanish. I conduct compliance and IT interviews in Spanish, review Spanish-language documentation, and deliver findings your U.S. banking partners can read in English — closing the gap that usually slows cross-border onboarding.

Crypto AML compliance FAQ

How does AML compliance apply to crypto companies?+

Crypto exchanges, VASPs, and many payments companies are treated like other financial institutions for anti-money laundering purposes. That generally means a written AML program, KYC and customer due diligence, sanctions screening, transaction monitoring, suspicious activity reporting, recordkeeping, and training.

What is the difference between KYC and AML?+

AML (anti-money laundering) is the overall framework of controls a business uses to detect and prevent financial crime. KYC (know your customer) is one component of it — the process of verifying customer identity and assessing risk at onboarding and over time.

When should a crypto company get an AML audit?+

Before a bank onboarding or regulatory examination, after rapid growth or expansion into a new market, when a banking partner or regulator raises questions, and periodically as part of good governance. An independent review is far cheaper than a remediation order or a closed account.

Related reading

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Is your AML program ready to be tested?

Whether you're preparing for a bank onboarding or a regulator already has questions, I'll assess where you stand and what it takes to be examination-ready.