A tailored AML framework is not a policy with the applicant’s name inserted. It begins with product, customers, geography, assets, custody, cash exposure, providers and transaction behaviour, then configures controls around those risks.
Risk assessment drives acceptance
Define prohibited, restricted and enhanced-review customers, countries, assets, channels and counterparties. Make the score and approval authority understandable to staff and management.
Connect identity and transaction evidence
KYC/KYB, beneficial ownership, PEP/sanctions, source checks and KYT should feed one case and escalation process. Conflicting information or unexplained wallet behaviour must not remain in separate systems without resolution.
Design alerts for the real model
Rules and thresholds should reflect expected customers, volumes, corridors, assets, velocity, cash and counterparty risks. Record disposition, rationale, escalation and reporting decisions.
Counterparties and self-hosted wallets
Identify sending and receiving VASPs, assess their status and countries and define the evidence needed for self-hosted wallets. Unsupported or high-risk counterparties require a controlled hold, reject, return or enhanced-review route rather than an improvised decision.
Make the compliance officer independent and effective
The role needs access to customer and transaction data, authority to escalate and stop activity, direct management reporting and enough time and support for the risk. Conflicts and overrides should be visible and reviewed.
Test quality and management oversight
Sample files and alerts, measure backlog and ageing, review overrides, track training competence and provide management with useful risk and performance information.
Demonstrate one complete case
A strong rehearsal follows a high-risk customer from onboarding through a transaction alert, investigation, source request, decision, possible report, account action and quality review. Each step should produce an accountable timestamped record that can be retrieved in Georgia.
Test controlled exceptions
Repeat the exercise with a false positive, incomplete customer, self-hosted-wallet transfer and provider outage. A mature framework proves both when the company intervenes and why it can safely proceed after documented review. Every exception is recorded and tested.