AML Compliance Program FAQ
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Build a Risk-Based AML Framework That Keeps You Secure—and Regulator-Ready
An effective AML compliance program is more than a regulatory checkbox—it’s a business necessity. LawVisory helps investment advisers, fintech companies, token issuers, and financial service platforms design, implement, and maintain risk-based AML programs that meet U.S. and global standards.
Below are the most common questions clients ask when navigating Anti-Money Laundering requirements.
General Overview
An AML compliance program is a formal set of policies, procedures, and controls designed to detect, prevent, and report money laundering activities. It typically includes customer identification, suspicious activity monitoring, internal training, and recordkeeping protocols.
AML obligations apply to:
- Registered Investment Advisers (RIAs) with custody or fund structures
- Broker-dealers, money service businesses (MSBs), and fund administrators
- Cryptocurrency exchanges, DeFi protocols, and NFT platforms
- Banks, fintech's, and payment apps operating in or through the U.S.
LawVisory advises on whether and how your business is subject to AML laws.
AML programs in the U.S. are governed by:
- The Bank Secrecy Act (BSA)
- The USA PATRIOT Act
- FinCEN (Financial Crimes Enforcement Network)
- OFAC (Office of Foreign Assets Control – sanctions enforcement)
- State-level money transmission laws
LawVisory helps businesses comply with these overlapping requirements.
AML Program Components
The five key components are:
- Written AML Policies & Procedures
- Designated AML Compliance Officer
- Customer Identification Program (CIP)
- Ongoing Employee Training
- Independent Testing / Audits
LawVisory offers implementation and periodic audits for all five areas.
A CIP outlines how your business verifies the identity of clients before doing business with them. It includes:
- Required documentation (e.g., ID, address)
- Screening for sanctions or PEP lists
- Procedures for high-risk customers
We help you develop a customized CIP based on your business model.
- KYC (Know Your Customer) is a broader due diligence framework that includes assessing customer risk, behavior, and expected activity.
- CIP is specifically about verifying a customer's identity at onboarding.
LawVisory can help you design a tiered KYC approach based on customer type and risk level.
Suspicious Activity & Monitoring
Suspicious activity may include:
- Large or unusual transactions
- Sudden changes in account behavior
- Inconsistent identification or source of funds
- Crypto-to-fiat transfers with high velocity
- Use of privacy coins or obfuscation tools
LawVisory helps you create risk indicators and escalation procedures.
A SAR is a confidential report filed with FinCEN when your business detects activity that may involve money laundering, fraud, or other financial crimes. Even if no crime is confirmed, you are required to file if suspicion is warranted.
If you're a registered money services business (MSB) or financial institution under BSA definitions, then yes. RIAs and crypto platforms may also be required to file depending on their activities and regulatory classification. We’ll assess whether and when your firm must report.
Training, Testing & Recordkeeping
AML training should be conducted at least annually and whenever significant changes to law or internal policy occur. Training must be documented and include:
- Red flag awareness
- Escalation procedures
- Policy and tool updates
LawVisory offers customizable training sessions for small teams or enterprise compliance departments.
Independent testing (or auditing) of your AML program ensures it’s working effectively. It must be performed by:
- An external law firm or consultant
- Or an internal team not involved in day-to-day AML operations
LawVisory performs both initial gap audits and annual AML effectiveness reviews.
You must retain:
- CIP documentation (5 years)
- SAR/CTR records (5 years)
- AML policies and logs of training
- Audit results and remediation
LawVisory helps you establish a compliant and secure record retention policy.
Crypto, Fintech & High-Risk Business Concerns
Yes—especially those that:
- Convert fiat to crypto (or vice versa)
- Custody assets or operate wallets
- Facilitate token launches or decentralized exchanges
The FinCEN Guidance of 2019 and follow-on directives make AML/KYC a core requirement. LawVisory creates custom crypto-native AML frameworks.
If a DeFi platform has a central party that sets terms, controls funds, or earns fees, regulators may treat it like a financial intermediary. Even “fully decentralized” platforms may face civil or criminal exposure if AML violations occur. LawVisory advises DeFi projects on structuring, disclosures, and risk containment.
Key strategies include:
- Conducting annual AML risk assessments
- Screening new clients against OFAC/PEP lists
- Using tiered KYC/CIP based on geography and transaction type
- Regularly updating your policies and training
LawVisory provides full support—from policy drafting to daily oversight.
LawVisory AML Support
We offer:
- AML/CFT Policy Manual Drafting
- Custom CIP/KYC Frameworks
- Suspicious Activity Monitoring Procedures
- Employee Training Programs (Virtual or In-Person)
- Record Retention Policies
- Annual Independent AML Audits
- Ongoing outsourced AML officer or compliance team support
We offer:
- Flat-fee AML Program Setup Packages (ideal for RIAs or FinTech's)
- Monthly or quarterly support retainers
- One-time audits or document drafting
Pricing depends on complexity, risk tier, and geography. Request a custom quote today.
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