Digital Currency Companies

It will take more than an innovative business model and disruptive technology to win in today’s rapidly evolving Bitcoin ecosystem.  In early 2013, we founded CoinComply, the only risk and compliance solutions provider for Bitcoin companies, to meet the growing demand for compliance solutions in the digital currency marketplace and have since successfully assisted various sectors of the Bitcoin ecosystem.  Now, under Stratis Advisory, we can continue to help you overcome the compliance obstacles that represent the number one barrier to success for digital currency companies.

Founded by former compliance officers and AML/BSA experts, Stratis Advisory has a hands-on understanding of the operational compliance issues that can negatively impact product development, next stage funding and your company’s ability to establish banking relationships.  We maintain a portfolio of prominent venture capital-backed and incubator graduate companies in the digital currency ecosystem.

Whether your company is early stage or nearing transactional readiness, we can help you achieve the infrastructure, program readiness, and ongoing compliance you need to succeed.  Our tempCCO solution delivers on-demand risk, strategy and compliance expertise to digital currency startups, their board of directions, investors and banking partners.

Stratis Advisory can help you:

  • Understand and navigate the changing landscape for regulatory compliance requirements
  • Develop critical organizational infrastructure for compliance
  • Implement a robust, digital-currency specific BSA/AML Compliance Program
  • Obtain critical BSA/AML/OFAC training as required under the BSA
  • Execute U.S. state money transmitter licensing applications directly with the state licensing department
  • Obtain surety bonds for state money transmitter licenses
  • Support your designated Compliance Officer in scaling operations and ensuring ongoing risk mitigation and management
  • Outsourced due diligence, investigations, and suspicious activity reporting
  • Conduct a comprehensive independent test of your digital currency company to meet your BSA requirements and onboarding and due diligence requirements of banks
  • Serve as a trusted advisor with banking partners on managing banking relationships
  • Cost-effectively achieve the level of compliance you need to maintain banking and customer relationships
  • Provide pre-FinCEN/IRS MSB BSA/AML examination (also known as a Title 31 Exam) assessment
  • FinCEN/IRS MSB BSA/AML exam management
  • Managing corrective action remediation from Title 31 exam, independent test, and any other gaps in the BSA/AML program

Contact us for more information

Engagement Profiles:

AML/BSA/OFAC Compliance Program for Bitcoin Startup

Situation and Background: A prominent VC-backed bitcoin startup needed to establish an AML/BSA/OFAC policy and program to support its growth and open transaction banking accounts to begin operations.

Key Issues:

  • Firm needed trusted advice in developing a right-sized compliance program that adequately mitigated and managed all of its AML/BSA risks.
  • Firm needed assistance with AML/BSA compliance infrastructure, including vendor selection.
  • Firm sought on-going support to secure banking relationships and guide compliance operations.


  • Conducted a robust and in-depth assessment of risks specific to the client’s market and business model.
  • Developed an AML/BSA/OFAC policy and program.
  • Initiated and participated in conversations with banks and vendors of CIP/KYC and transaction monitoring solutions.
  • Supported CCO and firm’s compliance operations during build-out and ramp-up of the compliance program.
  • Supported communications and due diligence with banking partners.

TempCCO AML/BSA Expertise for Bitcoin Hardware Supplier

Situation and Background: Prominent incubator graduate Bitcoin startup engaged in developing and distributing hardware globally with downstream implications as money transmission.

Key Issues:

  • Firm sought on-going AML/BSA compliance expertise support to guide existing business model and operations.
  • Firm needed to understand the AML/BSA compliance requirements and where risk may exist in certain process workflows.
  • Firm sought methods to enhance efficiency of compliance requirements to assist clients in operating firm hardware.


  • Provide on-going AML/BSA compliance strategy expertise to guide existing business model and operations.
  • Review pre-configured hardware, platform, and agreements for AML/BSA compliance.
  • Digest proposed enhancements to business model or global strategy to understand AML/BSA implications.
  • Analyze operating model for implications of money transmission.

AML/BSA Transaction Monitoring Rule Assessment for MSB

Situation and Background: Bitcoin startup needed to establish risk-based transaction monitoring rules to monitor customer transactions for unusual or suspicious activity.

Key Issues:

  • Firm needed trusted advice in developing risk-based transaction monitoring rules to assist with identifying unusual or suspicious customer transactions.
  • Firm sought to document rule selection process as part of its AML/BSA program requirements.


  • Conducted an assessment of money laundering risks specific to the client’s geographic market and business model.
  • Recommended specific rules to monitor customers transactions to assist with identifying unusual or suspicious transactions.
  • Drafted report providing analysis of rule selection, rule description, and any gaps in monitoring that may need to be addressed.