This is a redacted sample based on a digital asset exchange profile. Your Snapshot is scoped to your specific entity, licenses, and activities.
Delivered as a board-ready DOCX within 5 business days of questionnaire completion.
[CLIENT NAME] operates a centralized digital asset exchange offering spot trading, fiat on/off ramps, and custodial wallet services to retail and institutional customers in the United States. The firm holds active money transmitter licenses in 34 states and has a pending BitLicense application with the New York Department of Financial Services.
This Readiness Snapshot assesses regulatory exposure across 7 applicable regulatory regimes encompassing 127 mapped requirements. The assessment identified 12 findings — 3 higher-priority, 5 moderate, and 4 lower-priority — requiring remediation attention.
The most critical gaps involve incomplete suspicious activity monitoring coverage for cross-chain transactions, absence of a formalized OFAC screening validation program, and a gap in the firm's BSA independent testing scope. These represent areas that would likely receive examiner attention and may result in matters requiring attention (MRA) or matters requiring immediate attention (MRIA) designations.
The following regulators have jurisdiction over [CLIENT NAME] based on entity type, licensed activities, and operational scope.
| REGULATOR | BASIS | REQS | TIER |
|---|---|---|---|
| FinCEN (BSA/AML) | MSB registration; money transmission and exchange activities under 31 CFR Chapter X | 21 | TIER 1 |
| OFAC (Sanctions) | U.S. person engaging in financial transactions subject to IEEPA and OFAC regulations | 16 | TIER 1 |
| NYDFS (BitLicense) | Pending BitLicense application; virtual currency business activity in New York | 24 | TIER 1 |
| State MTL | Active money transmitter licenses in 34 states | 18 | TIER 1 |
| SEC | Token listings may include digital asset securities; exchange anti-fraud provisions | 20 | TIER 1 |
| CFTC | Spot digital commodity transactions; anti-manipulation provisions | 18 | TIER 1 |
| GENIUS Act | Stablecoin listing and custody activities; payment stablecoin reserve requirements | 9 | TIER 1 |
Token Taxonomy (SEC/CFTC Joint Interpretation) also assessed. OCC and CFPB determined not applicable based on entity type and activity scope — rationale documented in full report.
Findings are formatted in MRA/MRIA style with regulatory citation, description, remediation path, and target timeline. Shown below are 4 of 12 findings from this assessment.
Findings ranked by severity with target timelines. Formatted for board presentation or examination response.
| ID | FINDING | SEVERITY | TIMELINE | REGULATOR |
|---|---|---|---|---|
| F-001 | Incomplete SAR Monitoring — Cross-Chain | HIGH | Immediate | FinCEN |
| F-002 | OFAC Screening Validation | HIGH | 30 days | OFAC |
| F-003 | ████████████████████ | HIGH | 30 days | SEC |
| F-004 | ████████████████████ | MEDIUM | 60 days | NYDFS |
| F-005 | BSA Independent Testing Scope | MEDIUM | 60 days | FinCEN |
| F-006 – F-012 | 7 additional findings in full report | |||
Every requirement in this Snapshot is classified using the DAC Hierarchy of Authority — a four-tier framework that reflects how examiners weight regulatory sources.
DAC provides mapped applicability and readiness analysis, not legal conclusions or guarantees of compliance. All regulatory mappings are based on publicly available statutes, regulations, and agency guidance. DAC has not independently verified client representations.