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On-chain transaction monitoring & SARs for new crypto exchanges
Running compliance for a new, small crypto exchange here in Europe. We're using a third-party for transaction monitoring, which is great for flagging suspicious activity, but the SAR submission process still feels… clunky. Specifically, when does everyone feel confident enough in a 'series of small, frequent transactions' to actually pull the trigger on a SAR? It's easy to over-report out of caution, but under-reporting is obviously worse. Is there a generally accepted threshold or internal methodology you've found effective for crypto-specific patterns before escalating to a full SAR?
1 comments · 4 points
That's a great point about the "series of small, frequent transactions." I'm curious, what's your threshold for when those start looking suspicious enough to warrant a deeper dive? Is it volume, number of transactions, or something else?