Advisor
Most financial institutions assume their financial crime controls sufficiently mitigate crypto-related risk. In reality, few can clearly demonstrate how effective or efficient those controls truly are. This false comfort leads to increasing exposure to high risk crypto activities, hidden unnecessary costs and risk of regulatory scrutiny or remediation. Below are some examples of control gaps found in practice.
Material shortcomings in risk detection
No clear or complete implementation of crypto in SIRA/EWRA or risk appetite, leading to increased residual risks that go unmanaged
Generic KYC and TM Guidance
KYC and TM guidance is not connected to risk appetite, leading to inconsistent risk classification of clients across the portfolio
Transaction Monitoring Noise
Large volumes of false positives in TM generate unnecessary manual labor and distract from genuine risk signals
Superficial SoF/SoW Assessment
Superficial assessment of Crypto Source of Funds and Source of Wealth leads to acceptance of clients who should be classified as unacceptable
Poor Evidencing
Inadequate documentation leads to high-risk and costly client offboarding procedures that could have been avoided
No dedicated MI on crypto control performance
Due to a lack of oversight, no coordinated management information is readily available to demonstrate control
The core problem: Fragmentation leading to poor oversight
Responsibility for crypto-related risk is spread across multiple teams—KYC, Transaction Monitoring, Compliance—without clear ownership. As a result, the organization lacks oversight leading to controls being inconsistent, misaligned, and often ineffective.
The consequence is twofold: material client integrity risks remain undetected or insufficiently mitigated, while operational costs continue to rise.
How to solve this
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Step 1: Clarifying impact of crypto risk in your organization
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Step 2: Crypto control gap-analysis
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Step 3: Crypto Financial Crime Risk Framework development and implementation
How you can work with me
Risk & Control Diagnostics
independent assessment of crypto financial crime risk exposure, control design and governance maturity
Control Framework
design your Crypto Financial Crime Risk Framework and embed this in the organization
Executive Advisory (Trusted Advisor)
ongoing or time-bound advisory support for senior leaders navigating crypto-related risk, regulation and strategic decisions
Assurance Services
clearly scoped interventions designed to deliver insights or direction without long-term advisory commitment, like reviews or second opinions
Speaking & Executive Workshops
private sessions for boards and senior leadership focused on crypto risk, governance and decision-making in complex environments
Training
see Crysk Institute