ICO Analysis: Coinfirm AMLT

07:00 06/12/2017

For financial institutions, the post-crisis period has had many defining attributes, chief among them being the ever-changing regulatory environment. Changes in regulation often require a shift in internal processes, impacting everything from profit margins to business growth. In recent years, securities watchdogs have had an even bigger bone to pick with Know Your Customer (KYC) and Anti-Money Laundering (AML) guidelines. It turns out the big banks simply weren’t doing enough around this costly area of regulation.

The advent of initial coin offerings (ICOs) has placed even more emphasis on KYC/AML requirements, especially for token raises deemed to be securities. As it turns out, the blockchain industry has already responded to KYC/AML requirements via SAFT, or the Simple Agreement for Future Equity framework. It remains to be seen whether SAFT can streamline investor accreditation and verification or whether it will create more problems than it tries to solve.

Coinfirm has been closely monitoring the evolution of KYC and AML policies over time, and is acutely aware of the challenges of formulating best practices. In response, the firm has launched the AMLT network to help companies address their KYC, AML and Counter Terrorist Financing (CTF) requirements.

As we eluded to earlier, these regulatory bottlenecks have already influenced the blockchain community. Despite the growth and widespread adoption of cryptocurrencies, Coinfirm says KYC/AML/CTF requirements are a “massive roadblock” to the industry’s long-term growth. If blockchain-based currencies want to continue scaling up and attracting mainstream investors, they need to adopt a system that protects them against high-risk transactions, clients and groups.

Against this backdrop, the ultimate goal of the Coinfirm project is to create the global cryptocurrency standard for AML/CTF.


Coinfirm is offering an audited ERC223 token that will be used for prepaid products and access rights within the network. Members of the network will also receive AMLT tokens for providing ratings and information on specific addresses (hence, the “democratic” element embedded into the system).

The token itself is an important cog in the Coinfirm AML/CTF platform. Users can not only spend tokens on verification services, they can receive AMLT for participating in the rating and verification process.

Of the 400 million AMLT tokens available, 210 million will be dispersed through the crowdsale, which runs from Dec. 12, 2017 through Jan. 30, 2018. The company has 120 million tokens allocated to a rewards pool for network members.


The AMLT project is backed by a team of more than 30 people specifically recruited from the blockchain industry and with domain experience in AML, compliance and anti-fraud management.

Pawel Kuskowski is the CEO and founder of the project. He brings to the fore many years of experience as an AML/CTF and compliance adviser, having worked with major financial institutions up to and including RBS.

Co-founders Pawel Aleksander and Jakub Fijolek serve the project in the capacities of CIO and CTO, respectively. Aleksander has a proven track record in fraud prevention and AML/CTF, while Fijolek brings with him IT and security expertise.

Grant Blaisdell and Maciej Ziolkowski round out the founding team members. Blaisdell appears to be the business brains behind the project, whereas Ziolkowski is the cryptocurrency expert.

In addition to the founders, AMLT has recruited a COO, delivery director, AML specialists, tech specialists and product owners. Suffice it to say, this is one of the most complete teams we’ve seen featured in an ICO.


AMLT is a powerful concept that is backed by a world-class team and solid technical specifications. The platform is also coming on to the scene at the right time, as ICOs and blockchain enterprises seek regulatory clarity around token issuance.


  • As the whitepaper rightly identifies, there is hefty competition in this space. Brands such as Elliptic, Chainanalysis, Scorechain and others are also involved in helping companies implement regulatory compliance. Although AMLT believes it is superior, an increasingly crowded market is a risk worthy of consideration. -2
  • If the plan is to make tokens more easily accepted and adopted by mainstream financial institutions, doesn’t that defeat the purpose of a decentralized cryptocurrency system? What about ICOs that only serve a utility function? Should they also be required to meet stringent KYC/AML requirements? We bring this up because that’s one of the challenges associated with SAFT. By listing your ICO on the SAFT, aren’t you raising the likelihood that your token will be deemed to be a security? That was one of the major contentions of a recent report from the Cardozo Blockchain Project. -2

Growth Potential

  • Although the cryptocurrency market is worth more than $350 billion, struggles with regulatory compliance have left the industry outside the purview of traditional banks. If cryptocurrencies want to access this market (and they do), they will need to meet the sector’s AML/CTF requirements. This suggests that demand for AML/KYC platforms like the one offered by Coinfirm will only rise. +3
  • From a personnel perspective, AMLT is absolutely stacked. On paper, it’s a perfect blend of blockchain experience, domain expertise and business prowess. Over 30 folks working on the project should leave investors feeling good about their prospects. +3
  • The AMLT platform provides tangible use cases and benefits for its users. AMLT users receive discounts to access the AML/CTF platform and associated reports. They also receive exclusive access to exclusive content. For AMLT network members, tokens are rewarded for contributing data on cryptocurrency addresses. +2
  • Coinfirm is already partnered with some of the major cryptocurrency players, including bitcoin, Dash and Ethereum. If you’re concerned about use cases, Coinfirm seems to have it covered. +3


Based on the above analysis, we arrive at a score of 7 out of 10 for AMLT. It’s a viable project, already with big-name partners and backed by one of the strongest teams we’ve seen in a token raise. Regardless of our opinion on financial regulation, these requirements are only intensifying. As cryptocurrencies become more mainstream, a platform like AMLT could become a conduit for future growth.

Investment Details

  • Type: Crowdsale
  • Symbol: AMLT
  • Token Sale: Dec. 12, 2017 – Jan. 30, 2018
  • Platform: Ethereum
  • Tokens Available Via ICO: 210 million
  • Minimum Pre-Sale Purchase: 500,000 AMLT

Featured image courtesy of Shutterstock.