Our client developed and implemented internal KYC and AML procedures to manage and effectively mitigate the money laundering and financing of terrorism for their digital asset trading business.
We reviewed their internal KYC and AML policies and guidelines by designing the appropriate review procedures in order to express an opinion on the adequacy and effectiveness of the procedures in the following areas:
- Customer Due Diligence
- Customer Relationship Management Database
- Monitoring of Existing Customers
- Record Keeping
Based on the results of our review, we recommended that certain specific KYC and AML should be enhanced but felt reasonably assured that the overall internal KYC and AML procedures are adequate to mitigate money laundering and financing of terrorism risk.