Practice · Services

Institutional-grade
compliance, audit & advisory
for regulated digital asset businesses.

Eight practice areas covering the full lifecycle of a regulated financial business: from license to operate, to running a defensible compliance program, to passing the diligence of a correspondent bank or institutional counterparty.

01 AML / CFT Programs 02 KYT & Monitoring 03 Travel Rule 04 Regulatory Advisory 05 VASP Licensing 06 Independent Audits 07 Correspondent Readiness 08 Operational Infrastructure
01 — PRACTICE

AML / CFT Programs

End-to-end financial crime programs designed against FATF Recommendations, sectoral guidance and the supervisory expectations of the jurisdictions where you operate or seek to operate.

  • Risk Assessment

    Enterprise-wide and business-line BSA/AML risk assessments using risk-based methodology aligned with FATF and supervisory guidance.

  • Policies, Procedures, Controls

    Drafting and refresh of AML/CFT policy, KYC/KYB, EDD, sanctions, PEP, source of funds/wealth and customer risk-rating procedures.

  • Customer Due Diligence

    CDD/EDD frameworks for retail, institutional and high-risk customer segments — including beneficial ownership and SoW/SoF protocols.

  • SAR / STR & Regulatory Reporting

    Drafting, review and submission protocols for suspicious activity, transaction and threshold reporting across multiple supervisors.

  • Training

    Role-based AML/CFT training programs for board, executive, compliance, operations and front-line staff with attendance & comprehension tracking.

aml-program · v3.2.1
PRODUCTION
RISK-001Enterprise risk assessmentAnnual
POL-014AML/CFT master policyv3.2 · 2026-Q1
PRO-022CDD & EDD procedurev2.8
PRO-031Sanctions screeningReal-time
PRO-047Transaction monitoring42 rules · calibrated
PRO-058SAR drafting workflowFinCEN aligned
TRN-103Board AML trainingAnnual · attested
02 — PRACTICE

KYT & Transaction Monitoring

Know-Your-Transaction frameworks for digital asset operators — covering wallet attribution, exposure scoring, chain analytics integration, rule calibration and case management workflows.

  • Wallet attribution & clustering

    Integration with chain analytics providers for source/destination attribution, cluster identification and beneficial-owner inference.

  • Risk scoring & thresholds

    Wallet, counterparty and transaction-level scoring with calibrated thresholds and exception-based review queues.

  • Sanctioned address screening

    OFAC SDN, UN, EU, UK consolidated lists applied at deposit, withdrawal and counterparty level.

  • Rule calibration & effectiveness

    Periodic rule-tuning, false-positive analysis and effectiveness testing — evidence packaged for supervisory review.

kyt · monitoring · live
MONITORING
RULE EFFECTIVENESS · 30D 42 rules
87.4%
▲ 2.1pp vs. prior period
Rule precision after calibration cycle
EXPOSURE BREAKDOWN CHAIN ANALYTICS
Exchange (regulated)62.3%
DeFi protocols18.7%
Self-hosted wallets12.1%
Mixers / privacy2.4%
Sanctioned / darknet0.07%
03 — PRACTICE

Travel Rule

FATF Recommendation 16 implementation for VASPs — covering protocol selection, counterparty due diligence (Sunrise Issue management), data quality, jurisdictional thresholds and supervisory reporting.

  • Protocol selection & integration

    TRP, IVMS101, OpenVASP, Sumsub Travel Rule, Notabene, Veriscope — selection and integration aligned with counterparty network.

  • Jurisdictional threshold management

    Per-jurisdiction threshold logic (USD 1,000 / 3,000 / EUR 1,000 / local equivalents) with audit trail.

  • Counterparty VASP due diligence

    Sunrise Issue management — risk-based diligence on non-compliant counterparty jurisdictions.

  • Self-hosted wallet protocols

    Verification protocols and risk-based handling of transfers to/from non-custodial wallets.

JURISDICTION COVERAGE · TRAVEL RULE FATF R.16
USAFinCEN — USD 3,000 thresholdACTIVE
EUTFR / MiCA — EUR 1,000 thresholdACTIVE
GBRFCA — no de minimisACTIVE
SGPMAS — SGD 1,500 thresholdACTIVE
UAEVARA / SCA — risk-basedACTIVE
DOMPre-VASP frameworkMONITORING
04 — PRACTICE

Regulatory Advisory

Legal opinions, structuring, licensing readiness and ongoing regulatory navigation for digital asset businesses operating across multiple jurisdictions.

Legal Opinions

Token classification, regulatory characterization, operational legality and cross-border opinions delivered to the standard expected by institutional counterparties.

Licensing Readiness

Jurisdictional fit, entity selection, application drafting, regulator interaction and post-license obligations for VASP, PSP, MSB, e-money and banking licenses.

Cross-Border Structuring

Multi-jurisdiction entity architecture, regulatory perimeter mapping, passport rights, host/home supervision and substance requirements.

FATF / GAFI Assessments

Mutual evaluation readiness, technical compliance review and effectiveness self-assessments against the 40 Recommendations.

Regulatory Gap Analysis

Side-by-side comparison of home, host and counterparty jurisdiction frameworks with prioritized remediation paths.

Compliance Documentation

Policy & procedure framework, governance documentation, board materials and counterparty packs.

05 — PRACTICE

VASP Licensing & Structuring

From jurisdictional selection through application, license issuance and ongoing supervisory obligations. We support VASP applicants across multiple regimes with the documentation depth supervisors expect.

REGIMEEl Salvador BCR DASP frameworkActive
REGIMEBahamas DARE ActActive
REGIMEBVI VASP Act 2022Active
REGIMECayman VASP regime (CIMA)Active
REGIMEPanama Law 254 (in implementation)Monitoring
REGIMEEU MiCA CASP authorizationActive
REGIMEUAE VARA & ADGM FSRAActive
REGIMEU.S. State MTL / FinCEN MSBActive
vasp-application · workflow
IN PROGRESS
Jurisdictional analysis
Phase 01 · Completed
Entity formation & substance
Phase 02 · Completed
AML/CFT framework draft
Phase 03 · Completed
Application submission
Phase 04 · In progress
5
Regulator Q&A
Phase 05 · Queued
6
License issuance
Phase 06 · Queued
7
Post-license obligations
Ongoing · Queued
06 — PRACTICE

Independent Audits & Assurance

Independent testing and assurance designed to meet the standards of Tier-1 correspondent banks, fund administrators and supervisory examinations.

AML Independent Testing

Annual independent testing of AML/CFT program effectiveness across design, implementation and operational performance.

  • Risk assessment review
  • Sampling methodology
  • Findings & remediation

KYT Effectiveness Reviews

Quantitative review of transaction monitoring rule performance, alert quality and case management throughput.

  • Rule precision & recall
  • False-positive economics
  • Tuning recommendations

Sanctions Control Testing

Real-time and batch screening control testing across customer onboarding, transaction screening and counterparty review.

  • List coverage validation
  • Match rule testing
  • L1 / L2 disposition review

Governance Reviews

Board composition, committee structure, three-lines model and reporting cadence assessment against international standards.

  • Three lines of defense
  • Board reporting quality
  • Tone-at-the-top

Operational Risk Reviews

Process risk mapping, key risk indicators, incident management and operational resilience against ISO 31000 / 22301.

  • Process risk inventory
  • KRI / KPI framework
  • BCP & resilience

Audit Remediation

Findings-to-closure remediation program management — root cause, design, implementation and validation.

  • Finding triage
  • Remediation roadmap
  • Closure validation
07 — PRACTICE

Correspondent & Counterparty Readiness

When a Tier-1 correspondent bank, custodian or fund administrator opens diligence on your operation, what they find should answer their questions before they're asked. Mercantil packages your operation to that standard.

  • Wolfsberg DDQ preparation

    Wolfsberg CBDDQ and ancillary DDQ drafting, evidence collection and Q&A management.

  • Investor / counterparty packs

    Data-room construction, narrative documentation and counterparty-grade compliance packs.

  • Periodic refresh management

    Annual and event-driven counterparty refresh cycles managed end-to-end.

COUNTERPARTY ACCEPTANCE RATE 12-MONTH AVG
0%
Correspondent bank
onboarding success
0d
Median time to
first acceptance
0
Account terminations
post-onboarding (24m)
0
Active correspondent
relationships
08 — PRACTICE

Operational Infrastructure

Treasury workflows, settlement governance, regulatory reporting and operational resilience designed for institutional throughput and supervisory defensibility.

Treasury workflows

Reconciliation, custody segregation, settlement and treasury operations design.

Regulatory reporting

SAR/STR, CTR, large-value, threshold and supervisory return automation.

Risk escalation

Three-lines escalation paths, materiality thresholds and board reporting cadence.

Operational resilience

BCP / DR, third-party risk, cyber incident response — ISO 22301 alignment.

Sectors

Sectors we serve.

Mercantil's practice is built around the operational reality of regulated digital asset businesses — each sector has its own risk profile, supervisory exposure and counterparty expectations.

VASPs & Exchanges

Centralized exchanges, retail brokerages and institutional venues — licensing, listing, custody and operational compliance.

OTC Desks

OTC operators — counterparty diligence, settlement risk, large-trade reporting and correspondent relationships.

PSP / MSB

Payment service providers, money service businesses — licensing across U.S. states, EU PSD2 / EMI, and LATAM regimes.

Digital Banks & Neobanks

Digital banking license readiness, banking-as-a-service compliance, and core banking operational frameworks.

Cross-Border / Remittance

Corridor compliance, FX licensing, sender/recipient verification at scale, sanctions and screening orchestration.

Stablecoin Issuers

Issuer compliance, reserve attestations, redemption controls, MiCA EMT/ART and U.S. stablecoin framework readiness.

Institutional Access

Engage Mercantil.

NDA from first conversation. Practice intake usually returns scope, fee structure and engagement letter within 5 business days.