Lysis reviewed the exchange’s AML/CTF framework which resulted to a successful maturity assessment review.
Crypto & Digital Assets
Independent Governance Review of a Crypto Exchange
A U.K. domiciled crypto exchange with global reach.
A requirement from the client’s payment processing partner to carry out an independent maturity assessment review of the exchange’s governance framework and operational controls.
Lysis conducted an independent maturity assessment of the exchange’s AML governance framework including the operational systems and controls utilising the Arctic Intelligence AML HealthCheck solution.
Lysis reviewed the exchange’s AML/CTF framework which resulted in the assessment where a percentage of 83% fully compliant were achieved and 17% achieved partial compliance, meaning compliance requirements were met but some gaps were identified. A remedial programme was set up for the 17% and consequently the payment processing partner was happy to keep the facilities open.
Our client had a substantial backlog of transaction alerts. They were concerned that these included a number of true positives that therefore indicated suspicious activity and required reporting.
Our client wished to gain an ACPR Payment Institution license in France and asked for Lysis' assistance to prepare all the documents and for general support during the application process.
A crypto asset custodian based in the U.K. with global reach approached Lysis with the request to assist them with the process to obtain registration from the FCA which would enable them to operate in the UK market as a crypto asset business. Due to the holding company’s strong global footprint, part of the FCA requirements for registration included the need for a UK based money laundering reporting officer (MLRO).
