Regulatory and industry focus
Innovative new financial services offerings are already in consumers' hands and adoption is increasing. Six segments of digital assets are expected to draw the majority of consumer and investment interest.
Crypto Regulatory Strategy & Support
Risk and compliance considerations and resources
Capital Markets
Securities regulators continue to monitor crypto markets for products and activities that run afoul of registration requirements and other securities regulations.
Stablecoins
Many U.S. and global regulatory authorities have stated that stablecoin issuers should be regulated similar to banks.
NFTs
The scope of NFT’s on the market is increasingly incorporating more traditional financial products such as real estate.
Custody and Exchange
Custody and exchange activities trigger money transmission requirements of U.S. and foreign jurisdictions.
DeFi and Liquidity
Lending/ borrowing of digital assets is enticing for traditional financial institutions, but large concerns loom for the safety of retail investors.
Web3
Rapid evolution in blockchain technologies will prompt continued regulation and analysis of web product governance.
A multidisciplinary approach
Current KPMG Financial Services Regulatory and Compliance Risk (FSRCR) activity in the cryptocurrency space acts as a first line of approach for companies, drawing in a multitude of KPMG service lines.
As cryptocurrency becomes more widely adopted, there is a growing need for various KPMG services, including license application and compliance assessment, risk and control assessments for banks engaging in cryptocurrency activity, BSA/ AML program development, cybersecurity consultations, audit support, and tax services.
Forensics
Cybersecurity
Accounting Advisory Services
Tech Risk Management
U.S. Regulatory Developments
Since the fall of 2021, regulatory authorities have been announcing their intent to solidify regulatory authority and create clearer expectations for cryptoassets and the entities interested in participating in related activities. An example of regulatory clarity provided, on November 18, 2021, the Office of the Comptroller of the Currency (OCC) released interpretive letter #1179, stating it is permissible for a bank to engage in cryptocurrency activities if the bank can justify to the OCC that they have controls in place to conduct the activity in a safe and sound manner.
Crypto and digital asset considerations
KPMG is actively working with crypto-native and traditional FSIs to establish and adapt compliance and risk management programs to integrate additional risk considerations into existing enterprise frameworks.
1
Planning
- Strategy Development
- Vendor Selection & Third Party Risk Assessment
- Commercial & Operational Due Diligence
- Licensing Assistance
2
Capability Development
- Crypto Risk Framework Alignment
- Risk and Control Self Assessment (RCSA) Process
- Compliance Program Development
- Custody Operations Control Assessment
- Custody Operations & Security Design
- Information Security Program Development
3
Production
- Disaster Recovery Design & Testing
- AML Transactions Monitoring
- Third Party Risk Management Uplift
- Wallet Key Generation Ceremonies
KPMG has extensive experience assisting institutions in the development and implementation of wide-ranging, business-as-usual compliance programs for their digital asset-related activities.
1
Representative Client
- Stablecoin Issuer
- International Payments Provider
- Online Travel Services Company and Global Quantitative Trading Firm
- FinTech Lending
- Digital Asset Bank
2
Key Risk Areas Addressed
- Technology
- Regulatory and AML/KYC
- Operations
- Tax and Financial Reporting
- Information and Cyber Security
3
Accelerators Used
- State-by-State Requirements Filing Inventory and Application Roadmap
- Regulatory Reporting Operating Model and Data Inventory
- Operational Policies and Procedures (Including AML and Cyber)
- Regulatory Change Management Program
- Digital Asset Risk Taxonomy
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Meet our team
Todd Semanco
Partner, Advisory, Financial Services Risk, Regulatory & Compliance, KPMG US
Damian Plioplys
Principal Advisory, Financial Services Risk, Regulatory & Compliance, KPMG US
Michael Sullivan
Principal, Advisory, FS Regulatory & Compliance Risk, KPMG US
John Caruso
Principal, Forensic, KPMG US
Matthew P. Miller
Principal, Advisory, Cyber Security Services, KPMG US
Todd Semanco
Partner, Advisory, Financial Services Risk, Regulatory & Compliance, KPMG US
Damian Plioplys
Principal Advisory, Financial Services Risk, Regulatory & Compliance, KPMG US
Michael Sullivan
Principal, Advisory, FS Regulatory & Compliance Risk, KPMG US
John Caruso
Principal, Forensic, KPMG US
Matthew P. Miller
Principal, Advisory, Cyber Security Services, KPMG US