Beyond Policies: Building an AML Programme That Works

What does it take to build an AML programme that actually works in practice?

In this episode of Compliance Champions, Delphine Forma speaks with Tigran Rostomyan, Founder & CEO of AML Incubator, about Canada's AML framework for crypto businesses and the practical realities of building an effective compliance programme.

Tigran explains how FINTRAC registration interacts with Canada's securities framework, the five core components of an AML programme, and why the risk assessment should be the foundation for the controls a firm puts in place.

The conversation explores the practical challenges of the Travel Rule, including unhosted wallets and missing counterparty information, as well as how firms can build effective transaction monitoring by bringing together KYC, customer behaviour, fiat and crypto activity, blockchain analytics and sanctions screening.

Delphine and Tigran also discuss key crypto financial crime typologies, suspicious transaction reporting and examination readiness, with a recurring theme throughout the conversation: having policies is not enough. Firms need to demonstrate that their AML controls are risk-based, properly implemented and effective in practice.