Last updated: 15 April 2026
Purpose and commitment
Crypto License Network is committed to the highest AML/CFT standards. We do not advise crypto licensing engagements without first running a structured customer-due-diligence process.
Regulatory framework
We operate consistent with: the UK Money Laundering Regulations 2017; the Proceeds of Crime Act 2002; the EU AML Directives (current package); the FATF Recommendations and Travel Rule; OFAC, EU and UK sanctions regimes; and the local AML frameworks of the offices we operate in.
Risk-based approach
Each engagement is assessed against a risk-based scoring matrix covering client type, jurisdiction, source of funds, product complexity and political exposure. Risk scoring drives the depth of due diligence applied — standard, simplified or enhanced.
Customer Due Diligence (CDD)
For all clients we collect and verify: identity (passport / national ID), address (utility bill or equivalent), beneficial ownership down to 25%+ thresholds (or lower where risk indicates), purpose and intended nature of engagement, and source of funds.
Enhanced Due Diligence (EDD)
Enhanced measures apply to PEPs, high-risk jurisdictions, complex or unusual structures, and any engagement where the standard process surfaces risk indicators.
Beneficial ownership
We identify ultimate beneficial owners (UBOs) at 25%+ thresholds, lower where risk indicates. UBO data is independently verified against public registries where available.
PEP and sanctions screening
All clients and connected persons are screened at engagement and ongoing against PEP and sanctions databases (WorldCheck, ComplyAdvantage or equivalent).
Source of funds and source of wealth
Source of funds is verified for the relevant transactions. Source of wealth is verified for higher-risk clients and where risk indicates.
Ongoing monitoring
Client risk is monitored throughout the engagement. Material changes (ownership, jurisdiction, product) trigger re-assessment.
Suspicious activity reporting
Suspicious activity is reported to the relevant Financial Intelligence Unit — the National Crime Agency (UK), FinCEN (US), or local FIU — without tipping off the client.
Record keeping
Engagement records are retained for a minimum of seven years post-engagement (UK MLR 2017 standard).
MLRO
An MLRO is appointed and accountable for the AML programme. The MLRO has direct reporting access to senior management.
Training
All staff complete AML training at induction and annually thereafter, calibrated to role.
Engagements we will not accept
- Sanctioned persons or entities, or any structure intended to circumvent sanctions
- Anonymous structures where ultimate beneficial owners cannot be verified
- Engagements involving fraud, market manipulation, or known illicit-finance typologies
- Engagements where source of funds cannot be evidenced to a credible standard
- Politically-exposed clients where enhanced due diligence cannot be reasonably completed