Nils Silinevics
Partner · AML & Crypto Compliance · Former FIU Investigator
Your exchange initiated an Anti-Money Laundering review — examining your transaction behavior, not just your identity. AML reviews are more complex than KYC because they analyze patterns: fund origins, transaction chains, risk scoring from blockchain analytics providers like Chainalysis. Our lead partner spent 7+ years as a Senior AML/CFT Investigator at a European Financial Intelligence Unit — he knows how AML systems generate flags because he used to review them from the other side.
AML vs KYC: KYC verifies who you are. AML examines what you're doing. You can pass KYC perfectly and still trigger AML review based on transaction behavior. AML reviews require different documentation — transaction explanations, not just identity documents.
How AML monitoring works: Exchanges use providers like Chainalysis, Elliptic, or Crystal to assign risk scores to every transaction. If your deposit came from an address that — anywhere in its history — interacted with a flagged entity, your transaction inherits risk. The monitoring looks for patterns: structuring (avoiding reporting thresholds), layering (rapid asset conversion), and velocity (deposit-withdraw cycles).
SAR implications: During AML review, exchanges may file Suspicious Activity Reports with financial intelligence units. They cannot tell you if a SAR was filed. Your responses during AML review may become part of a regulatory record — professional preparation is essential.
Our advantage: Former FIU investigator on staff. We build compliance narratives that address the specific typology flagged — not generic document submissions. This narrative approach is what separates successful resolutions from endless back-and-forth.
Each platform handles AML Review differently. Select yours for platform-specific guidance, timelines, and resolution strategies.
A critical legal concept in AML reviews is the tipping-off prohibition. Under FATF Recommendations, EU AMLD6, and the US Bank Secrecy Act (31 U.S.C. § 5318(g)(2)), if an exchange files a Suspicious Activity Report (SAR) with financial intelligence units, the exchange is legally prohibited from informing you that a SAR has been filed. 'Tipping off' — revealing that a SAR exists — is itself a criminal offense. This means the exchange literally cannot tell you the real reason for your account restriction in some cases. You will see a generic 'under review' or 'compliance requirements' message, but the actual reason (a SAR filing) cannot be disclosed. This creates an information asymmetry that makes self-resolution nearly impossible. We identify when a SAR has likely been filed based on the pattern of the exchange's responses and adjust strategy accordingly — shifting from documentation submission to legal representation.
Yes — exchanges are legally required to file Suspicious Activity Reports (SARs) when they identify potentially suspicious activity. They cannot tell you if a SAR has been filed (tipping-off is illegal). This is why professional legal representation is essential — your responses need to be carefully structured knowing they may become part of a regulatory record.
Automated monitoring flags: deposits from addresses with Chainalysis risk exposure, structuring patterns (amounts just below thresholds), layering behavior (rapid asset conversion), velocity triggers (deposit-withdraw cycles), P2P counterparty flags, and cross-exchange rapid movement. Each platform's monitoring has different sensitivity — we know the patterns each system flags.
Yes — we handle AML Review across 21+ platforms including Binance, Bybit, Coinbase, Kraken, OKX, KuCoin, MEXC, HitBTC, CEX.IO, Crypto.com, Gate.io, HTX, Bitfinex, WhiteBit, Changelly, ChangeNow, FixedFloat, and stablecoin issuers (Tether, Circle). Each platform has different compliance processes, timelines, and documentation requirements. We tailor our approach to each.
Two options: Fixed fee from €399 (pay upfront, fixed scope) or Success fee (percentage of recovered amount, no upfront payment). Both include a free initial case assessment within 6 hours. No hidden fees, transparent agreement before we start. We only charge for successful outcomes on the success fee option.
No. The tipping-off prohibition under 31 U.S.C. § 5318(g)(2) (US) and equivalent EU/UK laws makes it a criminal offense for the exchange to inform you that a SAR has been filed. You will never receive explicit confirmation that a SAR exists. We identify when a SAR has likely been filed based on indirect indicators: the exchange's response patterns, the duration of the restriction, and the nature of the compliance review. When a SAR is likely involved, we shift strategy from documentation submission to legal representation.
Potentially yes, if the review uncovers evidence of actual money laundering, sanctions evasion, or other financial crimes. However, the vast majority of AML reviews are triggered by false positives or legitimate transactions that simply look unusual to automated systems. If you have legitimate funds and can document their origin, an AML review should not lead to criminal charges. If there are underlying concerns, we assess the situation before any documentation is submitted to ensure that submissions don't inadvertently create legal exposure.
Our main practice for resolving AML review across all 21 supported exchanges.
Unusual situations beyond standard compliance — inherited crypto, unprovable source of funds, and more.
Our guide on crypto AML laws across Europe — documentation, legal strategy, and timelines.
Key terms: AML, KYC, SoF, EDD, SAR — explained in plain language.
Tell us what triggered the AML review and what documentation they requested. We respond within 6 hours.