- Client
- Digital-asset exchange (anonymized)
- Outcome
- Closed with no enforcement action
The problem
Three requests arrived in ten days: a state supervisor asking about listing files, a federal agency asking about a sanctions-screening miss, and a foreign authority asking the exchange to identify depositors behind a set of addresses. The compliance team had answers. They did not have one answer.
The risk was not only the underlying issue. It was inconsistent productions that would define the facts for every later reader.
The work
We took control of the record. Listing memos, screening alerts, and escalation emails were collected once, reviewed once, and produced against a single chronology. Where a screening miss was real, we said so, and we showed the control change that had already been made.
On the tracing requests, investigations counsel separated addresses the exchange could attribute with account-level evidence from addresses it could only cluster by heuristic. We did not let a vendor score become a factual admission.
The result
The inquiries closed without a filed action. The exchange entered a short, private remediation plan with the state supervisor covering listing governance and alert handling. Customer communications during the inquiry stayed factual, which mattered when a small number of users later threatened suit.