What Compliance Services Cover
Regulatory compliance for financial services firms involves far more than writing an AML policy. A functional compliance programme must align with the specific regulatory framework of every jurisdiction where you hold a licence or serve clients, be tailored to your actual business model and risk profile, and be maintained continuously as regulations evolve.
Our compliance services cover the full lifecycle: from pre-licensing gap analysis (identifying what you need to get licensed), through programme design and implementation (building the policies, procedures, and systems), to ongoing management (MLRO services, staff training, regulatory reporting, and audit preparation).
The core areas of compliance we cover include Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), Know Your Customer (KYC) and Customer Due Diligence (CDD), FATF Travel Rule for VASPs, EU MiCA for crypto-asset service providers, PSD2/PSR for payment institutions, US Bank Secrecy Act (BSA) compliance for US-regulated firms, MAS Notice PSN02 for Singapore payment firms, and bespoke frameworks for other regulated jurisdictions.
Core Compliance Modules
MiCA: EU Crypto Compliance 2024/2025
The Markets in Crypto-Assets Regulation (MiCA) is the EU's comprehensive framework for regulating crypto-asset issuers and service providers. It entered full application in December 2024, making it mandatory for any firm offering crypto services to EU clients to obtain CASP (Crypto-Asset Service Provider) authorisation from their home member state regulator.
MiCA covers ten categories of crypto-asset services: custody and administration, operation of a trading platform, exchange against fiat, exchange against other crypto-assets, execution of orders, placing, reception and transmission of orders, portfolio management, advice, and transfer services. Firms providing any of these services to EU clients without authorisation face significant penalties and operational disruption.
CASP authorisation requires a detailed application including: governance and organisational requirements, capital adequacy (minimum €50,000–€150,000 depending on service category), AML/KYC programme, cybersecurity policies, conflicts of interest policy, complaints handling, business continuity, outsourcing policy, and a detailed business plan. Our MiCA compliance service guides you through the full application process and ongoing compliance requirements.
MiCA Transition: Firms licensed under national frameworks (e.g., German BaFin crypto custody, French DASP, Lithuanian VASP) have until July 2026 to obtain full MiCA authorisation. Starting the process early is strongly recommended — NCAs are already reporting application queues of 12–18 months.
FATF Travel Rule Implementation
The FATF Travel Rule (Recommendation 16) requires Virtual Asset Service Providers (VASPs) to collect, verify, and transmit information about originators and beneficiaries in crypto transfers. This is the most technically complex compliance requirement for crypto firms, requiring both a compliance framework and technical integration with Travel Rule solutions.
The threshold for Travel Rule obligations varies by jurisdiction: EU AMLD6 / TFR (Transfer of Funds Regulation) applies to all transfers regardless of amount; US FinCEN applies to transfers of $3,000 or more; most other FATF member jurisdictions apply a $1,000 threshold. For transfers to unhosted (self-custodied) wallets, additional verification requirements apply in most jurisdictions.
Technical implementation requires integration with a Travel Rule protocol solution. Major solutions include Notabene, Sygna Bridge, Shyft Network, and TRM Labs' TravelRule. Each integrates with different counterparty VASPs and has different jurisdiction coverage. We advise on solution selection, assist with technical integration, and design the operational procedures around Travel Rule compliance.
| Jurisdiction | Framework | Threshold | Unhosted Wallet Rules |
|---|---|---|---|
| EU | Transfer of Funds Regulation (TFR) | All amounts | Identity verification + self-declaration |
| USA | FinCEN Travel Rule / BSA | $3,000 | Enhanced due diligence |
| UK | Money Laundering Regulations | £1,000 | Risk-based assessment |
| Switzerland | FINMA VQF / SRO rules | CHF 1,000 | Strict — beneficiary verification required |
| Singapore | MAS PSN02 | SGD 1,500 | Permitted with enhanced CDD |
| UAE (ADGM/DIFC) | CBUAE / FSRA | AED 3,500 | Permitted with risk assessment |
PSD2 & PSR Compliance for Payment Firms
Payment institutions, e-money institutions, and account information service providers regulated under PSD2 (EU) or the Payment Services Regulations (UK) face extensive compliance requirements including safeguarding of client funds, strong customer authentication (SCA), open banking API obligations, and regulatory capital requirements.
The UK PSR (Payment Services and Electronic Money Regulations) diverged from EU PSD2 after Brexit but maintains broadly similar requirements. UK payment firms must comply with FCA expectations on safeguarding, operational resilience, and consumer duty (from July 2023), creating an additional layer of compliance obligations beyond pure payment regulation.
Our PSD2/PSR compliance service covers: safeguarding structure design (segregated accounts or insurance), SCA implementation review, operational resilience framework, regulatory capital monitoring, incident reporting procedures, open banking compliance (for AISPs and PISPs), and preparation for FCA/NCA supervisory reviews.
The Cost of Getting Compliance Wrong
Regulatory fines for AML and compliance failures in the financial sector have escalated dramatically since 2020. For crypto and fintech firms specifically, enforcement actions have resulted in nine-figure penalties, licence revocations, executive bans, and criminal referrals.
| Firm | Regulator | Fine | Breach |
|---|---|---|---|
| Binance | FinCEN/DOJ/OFAC | $4.3 billion | AML / sanctions violations |
| BitMEX | FinCEN/CFTC | $100 million | BSA / KYC failures |
| Kraken | OFAC/FinCEN | $362 million | Sanctions + BSA failures |
| Robinhood Crypto | NYDFS | $30 million | AML / cybersecurity |
| Bitfinex | NYDFS/CFTC | $42.5 million | Reporting / customer protection |