Cryptoasset Transaction Monitoring Advisory
Cryptoasset monitoring links activity visible on public or permissioned ledgers with customer, platform and fiat-payment context held elsewhere. Advisory work considers how those sources support the firm's monitoring goals and where their limits affect analysis.
Connect ledger activity with customer and payment context
Start with the activity and risk in question. Depending on the business model, this may span on-chain transfers, exchange or custody activity, fiat payments, customer records, counterparties and off-chain events. Sources differ in coverage, identifiers, timing and reliability. A ledger address alone does not establish who controls it or why activity occurred.
An initial discussion can map visible events and customer relationships, attribution evidence, data gaps and assumptions used to link records. It can consider which risk patterns relate to the firm's products and jurisdictions and whether scenarios reflect them without relying on a single indicator.
Examine coverage, scenarios and alert handling
A review may follow activity coverage and data inputs through scenarios, thresholds, alert triage, investigations and feedback. Evidence can include risk assessments, data mappings, scenario rationale, change records, workflows and a defined case sample. Agree the period, entities, activity types, systems, decision owners and limits of available evidence.
FATF guidance addresses virtual assets and providers but notes it does not reflect later standards revisions, including the 2025 changes to Recommendation 1. Check applicable domestic rules and supervisory expectations for each entity, activity and jurisdiction.
Understand analytical limits
Analysis depends on coverage, context and decision processes. Limitations can include missing off-chain information, incomplete attribution, third-party data, changing services and sample boundaries. Monitoring evidence alone cannot establish who controls a wallet or prove criminal conduct.
Trevor Barritt spoke at a Z/Yen event in 2020 about cryptocurrency risk controls and technology, including KYC and AML. The session reflects his work discussing controls for cryptoasset activity.
Common questions
Can this work identify the person behind a wallet?
No wallet-identification or forensic tracing service is represented. Monitoring questions can consider what attribution evidence an organisation holds and how its limits affect risk decisions.
Does on-chain monitoring show the complete customer relationship?
Not necessarily. Customer, account, fiat-payment and off-chain context may be held in separate systems or unavailable. Any review should state which sources and relationships are in scope.
Can the same monitoring scenarios work across jurisdictions?
That should not be assumed. Activity, products, data, legal obligations and supervisory expectations vary. The relevant jurisdictions and scope must be established before conclusions are drawn.