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.
Following a visit from the regulator, a global inter-dealer broker was put under a Section 166 order.
The client is incorporated in Ireland as an Irish Collective Asset-management Vehicle (ICAV). The client is an American investment fund which specialises in lending large amounts of money to various entities ranging from listed entities to unregulated entities based in the USA.
The merger of two global investment banks required the implementation of a single client onboarding firm structure and alignment of systems and procedure to a single global policy.
