<100 subscribers


Two Kinds of Compliance
Inside the industry we joke that there are only two types of compliance:
Compliance for the regulators.
Compliance that actually works.
The first is Compliance Theater: a beautifully lit stage where flawless procedures matter more than catching criminals, and glossy reports pacify investors. The props are expensive, the actors recite polished scripts, and as long as the audience (the regulator) applauds, funding and licences flow.
The most dazzling prop of all is the zombie system—software that ticks every box, flashes green 24/7, yet has long since lost its soul. KYT (“Know Your Transaction”) is the star zombie. It lives on the servers, blinks reassuringly, churns out spreadsheets—until a real bomb explodes right under its nose. You thought you bought a sentry; you’re actually feeding a corpse.
Act I: Autopsy of a Zombie—How Your KYT Dies Quietly
A zombie is not born from one catastrophic failure but from a slow, daily surrender of perception, analysis, and will. The autopsy reveals two parallel causes of death: technical brain-death and process cardiac-arrest.
Technical Brain-Death
1. Single-Tool Blindness: One Eye, 360° Battlefield
Relying on a single KYT vendor is the fastest way to go blind. A July 2025 study by Singapore-licensed MetaComp examined 7 000 real transactions and found that one-vendor screening missed up to 25 % of high-risk flows—a quarter of the battlefield simply invisible.
Figure 1 – False-Clean Rates by Tool Stack
Single vendor: 24.55 %
Two vendors: 22.60 %
Three vendors: 0.10 %
Why the gaps?
Regional bias: some feeds are tight with U.S. LEAs, others with Asian cyber-police.
Risk-type focus: one excels at OFAC hits, another at mixer detection.
Update lag: a risky address can die and be reborn faster than the slow feed notices.
Betting on one vendor is not risk management; it’s roulette.
2. Data Malnutrition: Starving the Brain
KYT is only as smart as the data it ingests. When KYC, risk-rating and business systems live in separate silos, the KYT engine receives stale snapshots instead of live context. A customer flagged “low-risk” three months ago may have morphed into a high-risk churner, but the KYT engine never hears about it. With no behavioural baseline, every ping becomes noise, and noise becomes silence.
3. Static Rules: Sailing with Last Year’s Map
Money-launderers evolve. Today they peel-chain through DeFi bridges and wash profits via NFT wash-trades. Yet many zombie systems still rely on 2019-era rules: “>USD 10 000 → alert.” Attackers simply script 1 000 micro-transactions. The system, unable to learn, drowns in false positives while missing the actual pattern.
Process Cardiac-Arrest
1. “Go-Live = Victory” Delusion
Too many fintechs treat KYT deployment like a wedding, not a marriage. Once the vendor logo appears in the compliance deck and regulators sign off, the budget and head-count evaporate.
Thresholds calcify.
Models never retrain.
New typologies go unnoticed.
The race-car is parked and rust begins.
2. Alert Fatigue: The Last Straw
An unmaintained system can generate 95–99 % false positives. Analysts start their mornings staring at hundreds of tickets, 90 % of which are “customer bought coffee with crypto.” They learn keyboard shortcuts to close cases faster than they read them. When the real alert arrives—buried in the haystack—muscle memory kills it in three clicks. The heart stops.
A Cautionary Tale
A friend’s company once bought the “Rolls-Royce of KYT” to dazzle regulators and investors—then cheaped out on a single-vendor licence. Static templates were deployed by an under-staffed, non-technical compliance team.
As transaction volume surged, the alert storm arrived. Analysts pivoted from investigating risk to clearing tickets. A professional laundering ring noticed. They smurfed gambling proceeds through thousands of sub-threshold transfers disguised as e-commerce payouts. The first real alarm came—not from the KYT zombie—but from their correspondent bank. Days later the regulator’s letter landed; the licence was revoked.
Figure 2 (MetaComp) shows Tron carrying a markedly higher share of “severe” risk transactions than Ethereum. Geography and chain choice matter—unless your KYT is already undead.
Epilogue
The story above is a mirror held up to hundreds of fast-growing fintechs across Southeast Asia. They have not collapsed—yet—only because the organized criminals have not bothered to knock. That is a matter of time, not luck. The curtain is still up; the audience is still clapping. But behind the scenes the zombies are feeding, and the next bomb is already ticking.
Two Kinds of Compliance
Inside the industry we joke that there are only two types of compliance:
Compliance for the regulators.
Compliance that actually works.
The first is Compliance Theater: a beautifully lit stage where flawless procedures matter more than catching criminals, and glossy reports pacify investors. The props are expensive, the actors recite polished scripts, and as long as the audience (the regulator) applauds, funding and licences flow.
The most dazzling prop of all is the zombie system—software that ticks every box, flashes green 24/7, yet has long since lost its soul. KYT (“Know Your Transaction”) is the star zombie. It lives on the servers, blinks reassuringly, churns out spreadsheets—until a real bomb explodes right under its nose. You thought you bought a sentry; you’re actually feeding a corpse.
Act I: Autopsy of a Zombie—How Your KYT Dies Quietly
A zombie is not born from one catastrophic failure but from a slow, daily surrender of perception, analysis, and will. The autopsy reveals two parallel causes of death: technical brain-death and process cardiac-arrest.
Technical Brain-Death
1. Single-Tool Blindness: One Eye, 360° Battlefield
Relying on a single KYT vendor is the fastest way to go blind. A July 2025 study by Singapore-licensed MetaComp examined 7 000 real transactions and found that one-vendor screening missed up to 25 % of high-risk flows—a quarter of the battlefield simply invisible.
Figure 1 – False-Clean Rates by Tool Stack
Single vendor: 24.55 %
Two vendors: 22.60 %
Three vendors: 0.10 %
Why the gaps?
Regional bias: some feeds are tight with U.S. LEAs, others with Asian cyber-police.
Risk-type focus: one excels at OFAC hits, another at mixer detection.
Update lag: a risky address can die and be reborn faster than the slow feed notices.
Betting on one vendor is not risk management; it’s roulette.
2. Data Malnutrition: Starving the Brain
KYT is only as smart as the data it ingests. When KYC, risk-rating and business systems live in separate silos, the KYT engine receives stale snapshots instead of live context. A customer flagged “low-risk” three months ago may have morphed into a high-risk churner, but the KYT engine never hears about it. With no behavioural baseline, every ping becomes noise, and noise becomes silence.
3. Static Rules: Sailing with Last Year’s Map
Money-launderers evolve. Today they peel-chain through DeFi bridges and wash profits via NFT wash-trades. Yet many zombie systems still rely on 2019-era rules: “>USD 10 000 → alert.” Attackers simply script 1 000 micro-transactions. The system, unable to learn, drowns in false positives while missing the actual pattern.
Process Cardiac-Arrest
1. “Go-Live = Victory” Delusion
Too many fintechs treat KYT deployment like a wedding, not a marriage. Once the vendor logo appears in the compliance deck and regulators sign off, the budget and head-count evaporate.
Thresholds calcify.
Models never retrain.
New typologies go unnoticed.
The race-car is parked and rust begins.
2. Alert Fatigue: The Last Straw
An unmaintained system can generate 95–99 % false positives. Analysts start their mornings staring at hundreds of tickets, 90 % of which are “customer bought coffee with crypto.” They learn keyboard shortcuts to close cases faster than they read them. When the real alert arrives—buried in the haystack—muscle memory kills it in three clicks. The heart stops.
A Cautionary Tale
A friend’s company once bought the “Rolls-Royce of KYT” to dazzle regulators and investors—then cheaped out on a single-vendor licence. Static templates were deployed by an under-staffed, non-technical compliance team.
As transaction volume surged, the alert storm arrived. Analysts pivoted from investigating risk to clearing tickets. A professional laundering ring noticed. They smurfed gambling proceeds through thousands of sub-threshold transfers disguised as e-commerce payouts. The first real alarm came—not from the KYT zombie—but from their correspondent bank. Days later the regulator’s letter landed; the licence was revoked.
Figure 2 (MetaComp) shows Tron carrying a markedly higher share of “severe” risk transactions than Ethereum. Geography and chain choice matter—unless your KYT is already undead.
Epilogue
The story above is a mirror held up to hundreds of fast-growing fintechs across Southeast Asia. They have not collapsed—yet—only because the organized criminals have not bothered to knock. That is a matter of time, not luck. The curtain is still up; the audience is still clapping. But behind the scenes the zombies are feeding, and the next bomb is already ticking.
Share Dialog
Share Dialog
No comments yet