WHAT WE DO
1. Crypto & Fintech Regulatory Advisory
1. Crypto & Fintech Regulatory Advisory
1. Crypto & Fintech Regulatory Advisory
Who this is for
Founders and leadership teams in crypto, fintech, or payments businesses, whether launching in one market or scaling globally.
The challenge
You're making decisions in a regulatory environment that's unclear, fragmented across jurisdictions, or intimidating. The cost of getting it wrong, through regulatory pushback, remediation, or lost opportunities, is high.
Common problems include: unclear business models under local virtual asset or payment services regulations, uncertainty on licensing triggers, weak AML/CFT frameworks copied from templates, and product features (yield, custody, token design, staking) that raise regulatory red flags.
How we help
We pressure-test your business model against regulatory expectations, translate complex rules into practical decisions, and design proportionate compliance approaches for your stage and risk profile, whether you're operating in Singapore, expanding to new markets, or building multi-jurisdiction compliance programmes.
This includes
- Mapping your products and flows against regulated activities in target jurisdictions
- Identifying gaps against AML/CFT and virtual asset requirements
- Designing risk-based controls: KYC/CDD, sanctions screening, transaction monitoring, asset safeguarding
- Preparing licensing applications and regulatory engagement strategies
- Advising on cross-border compliance structures as you scale
We have expertise in Singapore's Payment Services Act, MAS licensing (Standard and Major Payment Institutions), and PSN02 requirements for DPT service providers, as well as global VASP regulations, FATF Travel Rule implementation, and emerging frameworks for stablecoins and DeFi.
2. INTERNAL INVESTIGATIONS
1. Crypto & Fintech Regulatory Advisory
1. Crypto & Fintech Regulatory Advisory
Who this is for
Senior leadership, compliance, risk, or HR teams.
The challenge
You've received a whistleblower complaint, an allegation of bribery, fraud, conflict of interest, or employee misconduct. You need assurance the situation is being handled properly, proportionately, and defensibly, without moving too slowly or overreacting.
Common situations include: suspected bribery of public officials, conflicts of interest in vendor selection, misuse of company funds, retaliation against whistleblowers, and failures to escalate red flags tied to varying regulatory obligtaions.
How we help
We assess sensitive situations early, advise on scope and risk, lead or guide investigations, and help leadership make defensible decisions.
This includes
- Early triage and scoping
- Evidence and document review
- Conducting interviews
- Coordinating with external counsel where needed
- Producing clear findings reports with recommendations on discipline, remediation, regulatory reporting where required, and control fixes that address root causes
3. Anti-Bribery and Corruption Compliance Programmes
3. Anti-Bribery and Corruption Compliance Programmes
3. Anti-Bribery and Corruption Compliance Programmes
Who this is for
Organizations operating in high-risk markets, dealing with government counterparties, or managing complex third-party relationships.
The challenge
You need an anti-bribery programme that goes beyond generic policies and actually protects the organization. Whether you're facing regulatory expectations, investor due diligence, or preparing for M&A, you need something that works in practice and holds up under scrutiny.
Typical problems include: inherited "paper programmes" that don't reflect actual risks, weak third-party due diligence that misses red flags, no clear escalation pathways for conflicts of interest or gift and hospitality issues, fragmented approval processes across regions, and training that doesn't stick or change behavior.
How we help
We design and implement proportionate ABAC programmes anchored in your actual risk profile, taking into account the markets you operate in, the government touchpoints you have, and the third parties you rely on.
This includes
- Conducting structured bribery and corruption risk assessments
- Designing or simplifying ABAC policies, approval workflows, and escalation procedures
- Building risk-based third-party due diligence frameworks (agents, distributors, consultants, joint venture partners)
- Defining gift, hospitality, and sponsorship controls that are workable
- Training programmes that address real scenarios your teams face
- Creating realistic review cycles aligned with evolving enforcement expectations
The goal is a programme that protects the organization in substance, enables the business to operate, and demonstrates credible commitment to boards, regulators, and law enforcement.
We have expertise in the U.S. Foreign Corrupt Practices Act (FCPA), UK Bribery Act 2010, and Singapore's Prevention of Corruption Act, as well as OECD Anti-Bribery Convention standards and enforcement expectations from the U.S. Department of Justice, UK Serious Fraud Office, and Singapore's CPIB.
4. Crypto Compliance Programmes
3. Anti-Bribery and Corruption Compliance Programmes
3. Anti-Bribery and Corruption Compliance Programmes
Who this is for
Crypto, fintech, and digital asset businesses that need compliance structures which work in practice, not just on paper.
The challenge
Compliance is either missing, over-engineered, or fragile and likely to fail as the business grows or comes under regulatory scrutiny. You need something robust enough to satisfy regulators and stakeholders but lean enough to be sustainable.
Typical problems include: unclear board and management roles and governance structures, unclear scope of AML/CFT obligations for your business model, copy-pasted KYC procedures that don't match your risk profile, missing or weak transaction monitoring, inadequate sanctions screening, no STR governance or MLRO escalation pathways, and compliance frameworks that don't account for DeFi, staking, custody, or cross-chain activity.
How we help
We design proportionate crypto compliance programmes anchored in the regulatory requirements that actually affect your risk profile, whether that's MAS requirements in Singapore, multi-jurisdiction VASP licensing, or FATF-aligned AML/CFT standards.
This includes
- Conducting structured risk assessments for your products and customer base
- Designing or simplifying AML/CFT policies and procedures
- Building risk-based customer onboarding: KYC/CDD for retail, institutional, and counterparty relationships
- Defining transaction monitoring rules, thresholds, and escalation protocols appropriate to your volumes and risk
- Setting up sanctions screening across customers, transactions, and blockchain addresses
- Establishing STR governance and MLRO decision-making frameworks
- Implementing safeguarding controls for customer assets (if applicable)
- Setting up compliance metrics and reporting for senior management, boards, and regulators
- Creating realistic review cycles aligned with evolving MAS guidance, FATF standards, and international crypto regulatory developments
The goal is a compliance system that supports the business in substance, stands up when tested, and scales with your growth.