From Brokerage to Blockchain - Davies

From Brokerage to Blockchain

Developing an AML Framework for Crypto Trading Embedded in Brokerage Accounts

Financial institutions are rapidly adding crypto trading and blockchain based assets to their brokerage platforms. Many assume their existing anti‑money laundering (AML) controls will translate easily. They won’t. Crypto behaves differently from traditional assets, and its risks demand tailored controls.

Where Traditional Brokerage Models Fall Short

Traditional AML frameworks rely on predictable settlement, regulated intermediaries and known counterparties. Crypto breaks this model. Transactions occur on decentralised networks, ownership sits on public ledgers, and assets can move across chains within minutes. When customers withdraw to external wallets, assets leave the institution’s field of view. If firms treat crypto like equities or ETFs, they risk missing key red flags and creating gaps in sanctions and transaction‑monitoring programmes.

What a Modern Crypto AML Framework Needs

A successful framework starts with a clear operating model. Firms must define whether they act as execution agents, custodians, or providers of withdrawal and transfer services. Each activity carries distinct risks.

Customer risk profiling must also evolve. Static KYC is not enough. Institutions need dynamic segmentation that considers behaviour such as trading frequency, wallet usage, and interaction with decentralised services. Sanctions controls must pick up indirect exposure to high‑risk wallet clusters and suspicious transaction patterns, not just names.

Effective monitoring blends traditional surveillance with on‑chain insights. Analysts need clear guidance that explains how to use probabilistic blockchain signals without over‑relying on them. Strong governance then binds the framework together, ensuring transparency around thresholds, model choices and limitations.

Download the Full White Paper

Our full white paper explores these topics in detail, including practical examples, governance models and implementation guidance. If you’re planning to introduce crypto trading — or strengthen your current controls — download the complete report to access a clear roadmap for safe and compliant growth.

Meet the expert

Kunal Bavishi

Principal Consultant

Risk & Compliance

I am a CAMS-certified, Subject Matter Expert (SME) in financial crime and compliance, with over ten years of experience in regulatory and compliance technology.