| 1. |
VASPs should have effective AML/CFT controls and systems in place which can adequately manage the AML/CFT risks relevant to their VA Activities, including the use of distributed ledger analytics tools, as well as other investigative tools or capabilities to monitor and screen transactions. |
| 2. |
In respect of any distributed ledger analytics tools used, VASPs should review and document their review of the capabilities and weaknesses of such tools and design controls to monitor clients’ interaction with their VA Activities. |
| 3. |
Information about Virtual Asset transactions and VA Wallet addresses are dynamic in nature. VASPs should review and document their review of the performance and function of any distributed ledger analytics tools used to for ongoing monitoring. |
| 4. |
VASPs shall, if applicable, implement internal controls to address the FATF Report Virtual Assets Red Flags Indicators of Money Laundering and Terrorist Financing [September 2020] when designing transaction monitoring scenarios and thresholds to monitor clients’ interaction with their VA Activities.
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