AML compliance for smaller digital asset firms – am I overthinking this?

asked by u/wei_adams · 2d · 0 answers

Hey everyone, fairly new to the compliance side of things for a small digital asset exchange. We're obviously on top of the basics for AML, KYC for fiat on-ramps etc., but I'm looking at our transaction monitoring system for crypto-to-crypto trades. The volume isn't huge yet, but I'm trying to wrap my head around the 'suspicious activity' thresholding for things like rapid, small transfers between different wallet addresses without a clear business purpose, or sudden large transfers of less liquid tokens. Are we expected to scrutinize every single crypto-to-crypto transaction with the same lens as fiat, even when the value is relatively low and the counterparty is often unknown beyond their wallet address? It feels like we're either going to flag everything or miss something significant. How are larger or more experienced firms setting their rulesets for this, specifically for the lower-value, higher-frequency crypto movements?

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