Advisory
Advisory
For executive leaders in FEC, Compliance and Business
Taking demonstrable control of crypto financial crime riskMost 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 creates real consequences: increasing exposure to high-risk crypto activity, hidden operational costs, and growing vulnerability to regulatory scrutiny or remediation.I work directly with executive teams to close that gap — drawing on proven approaches developed in practice with Tier 1 institutions.
Where control gaps typically emerge
These are the most common gaps I encounter in practice — each one a source of regulatory exposure or unnecessary cost.
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
Responsibility for crypto-related risk is distributed across KYC, Transaction Monitoring, and Compliance — without clear ownership or coordination. The result is an organisation that lacks the oversight needed to demonstrate control.
The consequence is twofold: material client integrity risks go undetected or insufficiently mitigated, while operational costs continue to rise unchecked.
How to solve this
How I approach it
1
Clarifying impact. Establish how crypto risk manifests in your specific organisation — across client segments, business lines, and control functions. This creates a shared, evidence-based picture of actual exposure.
2
Control gap-analysis. A structured assessment of your current controls against regulatory expectations and best practice. Identifies where gaps exist, and what needs to change.
3
Risk Framework development and implementation. Design and embed a Crypto Financial Crime Risk Framework that integrates across KYC, TM, Compliance and Business — giving your organisation a single, coherent operating standard for crypto risk.
How you can work with me
Risk & Control Diagnostics
Independent assessment of crypto financial crime risk exposure, control design and governance maturity. The right starting point when you need a clear, credible picture before committing to a larger programme.
Control Framework
End-to-end design of your Crypto Financial Crime Risk Framework, embedded across the organisation. For leaders who need a structured, institution-wide solution aligned with regulatory expectations.
Executive Advisory (Trusted Advisor)
Ongoing or time-bound senior advisory support for leaders navigating crypto risk, regulatory developments and strategic decisions. Direct access, no intermediaries.
Assurance Services
Clearly scoped interventions - reviews, second opinions or targeted assessments - designed to deliver specific insights or direction without a long-term engagement. Useful when you need an independent view quickly
Speaking & Executive Workshops
Private sessions for boards and senior leadership on crypto risk, governance and decision-making. Built around your organisation's context, not a generic presentation. Includes one-on-one training.
Ready to take control?
If you recognise the gaps described above, the first step is a focused conversation about where your organisation stands and what would make the most immediate difference.