CASP Documentation Packages
From Foundation to Enterprise
Structured documentation designed to support every stage of your firm's compliance maturity.
FOUNDATION
For CASPs
A structured documentation package designed to establish the essential compliance framework for newly established Crypto-Asset Service Providers.
The package provides the core governance and AML/CTF documentation required to build a consistent documentation environment from the outset and supports firms in creating a structured compliance foundation aligned with their business model.
It is intended for firms building their documentation framework rather than reviewing existing documentation.
Areas covered
• AML/CTF Framework
Core policies establishing the firm's AML/CTF governance principles, compliance responsibilities and internal control environment.
• Business Risk Assessment
Identification and assessment of inherent money laundering and terrorist financing risks associated with the firm's activities.
• Customer Risk Framework
Methodology for customer risk classification, risk scoring and risk acceptance principles.
• Customer Acceptance Framework
Risk-based onboarding principles defining acceptable customer profiles and prohibited business relationships.
• Sanctions & PEP Controls
Documentation governing sanctions screening, politically exposed persons and escalation requirements.
• Suspicious Activity Reporting
Internal procedures for identifying, escalating and documenting suspicious activity.
• Record Keeping Standards
Documentation governing retention, storage and accessibility of compliance records.
Delivery
Approximately 2–4 weeks following completion of the intake questionnaire and receipt of documentation.
Format
Word / PDF
Written delivery only
Best paired with
Operations Documentation Package
OPERATIONS
For CASPs
A documentation package designed to translate governance principles into day-to-day operational compliance procedures.
The package expands the documentation framework by introducing customer lifecycle documentation supporting onboarding, monitoring and operational compliance activities.
Areas covered
• Customer Onboarding Procedures
Risk-based onboarding workflows for different customer categories.
• KYC & KYB Procedures
Customer identification, verification and beneficial ownership procedures.
• Enhanced Due Diligence Procedures
Additional verification and review procedures for higher-risk relationships.
• Ongoing Monitoring Framework
Customer review cycles and periodic reassessment methodology.
• Transaction Monitoring Procedures
Documentation governing transaction monitoring controls and alert handling.
• Screening Procedures
Sanctions, PEP and adverse media screening processes.
• High-Risk Customer Management
Governance for managing elevated-risk customer relationships.
• Compliance Monitoring Framework
Internal monitoring programme covering compliance controls and documentation reviews.
Delivery
Approximately 3–5 weeks.
Format
Word / PDF
Written delivery only
Best paired with
Governance Documentation Package
GOVERNANCE
For CASPs
A governance-focused documentation package designed to strengthen oversight, accountability and organisational resilience.
The package introduces governance documentation supporting management oversight, internal control and enterprise risk management.
Areas covered
• Compliance Governance Framework
Overall governance structure defining accountability and reporting relationships.
• Enterprise Risk Framework
Risk governance documentation supporting enterprise-wide risk management.
• Risk Appetite Statement
Documentation establishing the firm's overall risk tolerance.
• Three Lines of Defence Framework
Definition of governance responsibilities across operational management, compliance and independent oversight.
• Board Reporting Framework
Documentation governing compliance reporting to senior management.
• Internal Control Framework
Governance documentation supporting internal control activities.
• Outsourcing & Third-Party Oversight
Documentation governing outsourced activities and service providers.
• Regulatory Change Management
Procedures for monitoring and implementing regulatory developments.
Delivery
Approximately 4–6 weeks.
Format
Word / PDF
Written delivery only
Best paired with
Enterprise Documentation Suite
ENTERPRISE
For CASPs
A fully tailored documentation programme designed for firms requiring an enterprise-level documentation ecosystem.
Rather than adding predefined documents, this package focuses on documentation architecture, harmonisation and organisation-wide governance.
Areas covered
• Documentation Gap Assessment
Independent assessment identifying documentation gaps and improvement priorities.
• Documentation Harmonisation
Alignment of policies and procedures across business units and documentation sets.
• Group Governance Documentation
Development of governance documentation supporting multi-entity organisations where applicable.
• Prudential Documentation
Preparation of prudential governance documentation where required by the firm's operating model.
• Documentation Roadmap
Structured plan for future documentation development.
• Bespoke Policies & Procedures
Preparation of documentation addressing firm-specific operational or regulatory requirements.
• Documentation Architecture Review
Assessment of documentation consistency, structure and governance across the framework.
Delivery
Timeline agreed according to project scope.
Format
Word / PDF
Written delivery only
Best paired with
Specialist Documentation Modules
