A trust company providing digital asset custody and virtual currency settlements for institutional investors (e.g., hedge funds, private/investment companies), technology companies, cryptocurrency exchanges, and cryptocurrency ATM services retained StoneTurn to conduct an AML Program review. StoneTurn’s review included assessing whether the company’s policies, procedures, and controls (e.g., cryptocurrency-specific transaction monitoring, wallet screening) meet AML-and Sanctions-related regulations, including the Bank Secrecy Act, as amended by Title III of the USA PATRIOT Act and the Office of Foreign Assets Control of the United States Department of Treasury, and regulatory guidance (e.g., the Financial Action Task Force).