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Preparation of an Independent AML External Audit Report for a Virtual Asset Exchange

Delivery of an Independent AML External Audit Report for a Virtual Asset Exchange

사건 개요

Client Information: Corporate / Client

Case Details: A domestic virtual asset exchange (“Company A”) engaged Decent Law Firm to conduct an independent external audit of its Anti-Money Laundering (AML) framework, as required under the Act on Reporting and Using Specified Financial Transaction Information (the “Special Financial Transactions Act”) and Article 15 of the Operational Regulations on Anti-Money Laundering and Counter-Terrorist Financing (the “Operational Regulations”).

Under the Special Financial Transactions Act, Virtual Asset Service Providers (VASPs) are obligated to establish and maintain an AML system and to undergo an independent review at least once annually.

Amid increasing regulatory scrutiny from supervisory authorities, Company A sought an objective assessment of whether its AML framework complied with current legal and regulatory standards and to proactively identify potential compliance risks. For this purpose, the company retained Decent Law Firm’s Digital Asset & Virtual Asset Practice Group.

디센트 전략

Decent’s Digital Asset Practice Group conducted the audit in accordance with the FATF Recommendations, relevant FIU notices, and the Operational Regulations.

Using a proprietary AML audit checklist developed in line with these standards, we performed a comprehensive review through document analysis, interviews with responsible personnel, system demonstrations, and sampling-based testing. A formal external audit report was then prepared and delivered.

1. Evaluation Across Nine Operational Areas
- We assessed both the design and the actual implementation of AML controls across nine core areas, including:
- Governance
- KYC (Know Your Customer)
- EDD (Enhanced Due Diligence)
- WLF (Watch List Filtering)
- Travel Rule compliance
- STR (Suspicious Transaction Reporting)
- and other key AML control functions

Each area was evaluated and assigned a graded Level rating reflecting its operational maturity.

2. Identification of Vulnerabilities and Practical Recommendations
For each identified deficiency, we categorized risks by priority and provided concrete, actionable recommendations that could be immediately implemented within the client’s operational structure.

3. Board-Ready External Audit Report
We calculated an overall AML operational maturity rating and prepared a comprehensive external audit report suitable for submission to the Board of Directors.

결과 및 의의

"Delivery of an Independent AML External Audit Report for a Virtual Asset Exchange"

Decent Law Firm’s Digital Asset Practice Group delivered an independent AML external audit report grounded in the Special Financial Transactions Act, the Operational Regulations, and the FATF Recommendations.

Based on this report, the client was able to objectively assess the current state of its AML framework and proactively prepare for potential regulatory inspections.

For Virtual Asset Service Providers, an AML external audit is not merely a formal compliance requirement—it is the starting point of substantive regulatory risk management.

If your organization requires an AML external audit or a comprehensive review of your anti-money laundering framework, please contact Decent’s Digital Asset Practice Group.