IR Hotline Numbers:

+44 20 3318 1470
+60 154 877 0076
+61 2 7908 1745
+65 3165 8788
caution icon

Experienced a breach? Reach us now

company logo


Assisting a Digital Asset Company Create Localized AML/KYC Compliance Programme Documents

Assisting a Digital Asset Company Create Localized AML/KYC Compliance Programme Documents

The Background

The client is a leading blockchain technology service provider for services such as a wallet app (for retail customers) and custody and asset management services (for institutional clients). As one of the largest crypto asset custodians in Asia, its services are trusted by over 300 institutions and high-net wealth individuals to grow and preserve a total portfolio of over US$1B AuM.

In January 2020, the Monetary Authority of Singapore (MAS) issued the Payment Service Act (PSA) – a comprehensive regulatory framework for digital asset service providers. Besides adhering to this framework, affected organisations must now apply for a PSA license in order to commence (or continue) their operations in Singapore.

With plans to expand their digital asset footprint into Singapore, the client engaged Pragma's services into assist it in applying for a PSA license and, in the context of that application, to assist in the interpretation and implementation of relevant AML/CFT requirements.

The Process

To ensure that it's anti-money laundering/know your customer (AML/KYC) capabilities would satisfy MAS requirements, Pragma's Compliance, Conduct, and Regulatory Risk team was engaged to review and document the client's existing AML/KYC compliance programme.

The Result

Since the client's global AML/KYC compliance programme was insufficiently chronicled, Pragma's assisted in creating a comprehensive procedures document for the areas listed below.

  • Customer onboarding – e.g., document collection and verification, customer risk assessments
  • Ongoing customer monitoring – e.g., periodic reviews, transaction monitoring, responding to red flags
  • Information reporting – e.g., suspicious transaction reporting, regulatory authority requests
  • Recordkeeping – e.g., documentation storage and retention
  • Third parties/third party vendors
  • Internal policies, audits, and training

Though the procedures document focused on MAS requirements, it could be easily customized for other jurisdictions where the client operates. Where controls could be improved (and, thus, further reducing operational risk), such recommendations were provided to the client.


Digital Asset Company
AML/KYC Compliance Programme
Regulatory Framework
Payment Service Act (PSA)
PSA Licence Application
Singapore Expansion
Interpretation and Implementation
Anti-Money Laundering (AML)
Know Your Customer (KYC)
MAS Requirements
Compliance Programme Review
Customer Onboarding
Document Collection and Verification
Customer Risk Assessments
Ongoing Customer Monitoring
Periodic Reviews
Transaction Monitoring
Red Flags
Information Reporting
Suspicious Transaction Reporting
Documentation Storage and Retention
Third Parties/Third Party Vendors
Internal Policies
Operational Risk

Join the Pragma Community Today



Cyber Advisory

Technology Risk

Compliance, Conduct, and Regulatory Risk

IT Audit


Pragma Logo

Terms & conditions

Privacy Policy