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Business Transformed: Charting a Crypto Evolution From Consent Order to Supercharged Performance

A highly regarded and federally regulated crypto-native service provider (one that exclusively uses cryptocurrencies), entered into a consent order with the Office of the Comptroller of the Currency (“OCC”) to refine and enhance its anti-money laundering (“AML”) and compliance program.

With this vital transformation on the horizon, the bank turned to FTI Consulting to support it in its journey from a start-up mentality to a more established and compliance-first approach — improving the implementation and effectiveness of its AML and compliances controls and processes.

Our Impact

By refining the bank’s compliance framework, the client strengthened its automated blockchain monitoring (“ABM”) system, improved its third-party risk management (“TPRM”) program and enhanced its AML customer risk rating (“CRR”) tool and documentation ─ resolving any identified shortcomings and ensuring compliance with regulatory requirements.
Following a thorough assessment of the bank's cybersecurity program, actionable recommendations to enhance security measures were provided, ultimately reducing the risk of cyber threats and potential data breaches.
In addition to ensuring regulatory compliance, this refinement subsequently enhanced operational efficiency across various areas, likely resulting in future cost savings and improved risk management — strengthening banking partners’ relationship and confidence in the business.

Our Role

FTI Consulting performed an independent model validation of the bank’s ABM system — a market leading technology vendor — delivering a comprehensive validation assessment report with methodology, observations and recommendations.
We conducted a current state assessment of the bank’s TPRM program and used the results to drive enhancements across onboarding procedures, vendor selection, governance, inventory management and vendor selection.
Additionally, we assessed and improved the AML Customer Risk Rating (“CRR”) tool, enhancing functionality, procedures and the end-to-end process. Additionally, we assisted the bank in enhancing its Know Your Customer (“KYC”) processes for more than 400 high- and medium-risk customers, refining policies and procedures, leveraging an advanced AML CRR tool and verifying Customer Identification Program (“CIP”), Customer Due Diligence (“CDD”) and Enhanced Due Diligence (“EDD”) documentation.
FTI Consulting performed an independent assessment of the bank’s cybersecurity program, evaluating its security architecture, policies and procedures, as well the bank’s IT security controls, digital and dark web footprint exposure ─ resulting in a final assessment report with key actionable feedback on potential areas of vulnerability.