AML/CFT • KYC/KYB • KYT • SANCTIONS
AML, KYT & Financial Crime Controls in Web3
Connect customer due diligence with blockchain transaction intelligence, investigation, escalation and governance.
Knowledge Series
Web3 financial-crime controls must connect customer identity and expected behaviour with blockchain activity and the wider counterparty ecosystem. KYC alone does not establish the source or destination of funds; blockchain analytics alone does not establish identity, intent or legal status.
This article introduces a risk-based AML/CFT and financial-crime control framework for digital-asset businesses, including exchanges, custodians, wallet providers, payment businesses, tokenisation platforms and Web3 startups.
ALMR Web3 Security & GRC Knowledge Series
What this article covers
- Enterprise ML/TF/PF risk assessment
- KYC, KYB & beneficial ownership
- Enhanced due diligence
- KYT & blockchain analytics
Key Themes
Enterprise ML/TF/PF risk assessment
Assess products, services, customers, geographies, delivery channels, transaction patterns and blockchain exposure.
KYC, KYB & beneficial ownership
Identify and verify customers, legal entities, controllers and beneficial owners; understand expected activity.
Enhanced due diligence
Apply proportionate review of higher-risk customers, source of funds and source of wealth where required.
KYT & blockchain analytics
Use wallet screening, transaction monitoring, exposure analysis and risk indicators as investigative inputs.
Sanctions & value-transfer controls
Screen relevant parties and wallets; assess Travel Rule and transfer requirements where applicable.
Case management & governance
Document alerts, investigations, decisions, escalation, reporting, quality assurance and management oversight.
Management Review
- Does the risk assessment reflect products, customer types, geographies and on-chain exposure?
- Can the organisation identify customers, beneficial owners and expected transaction behaviour?
- Are blockchain analytics alerts investigated in context rather than treated as automatic proof?
- Are sanctions, higher-risk exposure, unhosted wallets and value-transfer controls addressed?
- Are escalation, suspicious transaction reporting and case decisions documented by authorised personnel?
A practical perspective
The objective is not to accumulate policies. It is to establish clear ownership, controls that address material risks, reliable evidence and a process for continuous improvement.
Implementation Considerations
Establish risk understanding
Map products, customers, geographies, channels, counterparties and material ML/TF/PF scenarios.
Design risk-based controls
Define CDD, EDD, sanctions, KYT, monitoring scenarios, escalation and case ownership.
Implement and test
Validate alert logic, investigation workflows, data quality, reporting routes and training.
Govern and improve
Monitor effectiveness, tune controls, review typologies and report material risks and trends.
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Frequently Asked Questions
Discuss Your Requirements
Get In Touch
Discuss your Web3 governance, risk, compliance, technology-risk or institutional-readiness requirements with ALMR Consulting.
Email:
team@almrconsulting.com
Phone:
+65 62233226
Address:
1 Wallich St #14-01
Guoco Tower, Singapore - 078881