AML compliance for smaller digital asset firms – am I missing something?
Been looking at the updated FATF guidance on VAs and VASPs again, specifically how it trickles down to smaller entities in the digital asset space. We're not a massive exchange, just a boutique firm helping with institutional onboarding and OTC for a specific niche. The sheer volume of documentation and ongoing monitoring requirements feels almost disproportionate for our scale and transaction volume. I get the 'risk-based approach' but practically, for smaller outfits, it seems like we're expected to implement solutions built for much larger operations without the corresponding budget or personnel. Is there a common interpretation or strategy for smaller VASPs to remain compliant without being completely swamped, or am I overthinking the 'risk-based' part and need to just suck it up and hire a full-time dedicated compliance officer even with a lean team?
I hear you. The scalability of AML frameworks is a real challenge for smaller players. Have you looked into any RegTech solutions that might automate some of these processes?