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C. Anti-Money Laundering and Combating the Financing of Terrorism [AML/CFT]

1. Issuers must comply with all Federal AML-CFT Laws as well as all other laws, regulation, rules and guidelines in respect of AML/CFT applicable to their business or operations in any jurisdiction at all times.
2. Controls and systems. Issuers should have effective AML/CFT controls and systems in place which can adequately manage the AML/CFT risks relevant to all Virtual Assets that they issue.
3. Risk assessment. In implementing adequate and appropriate AML/CFT policies, procedures, and controls to detect and prevent illicit activities, Issuers must conduct AML/CFT business risk assessments. The AML/CFT business risk assessments must be designed and implemented to assist the Issuer to better understand its risk exposure, and areas in which it should prioritise allocation of resources in its AML/CFT activities. This includes identifying and assessing the AML/CFT risks arising from the development and use of new or existing—
  a. Virtual Assets [in particular, Anonymity-Enhanced Cryptocurrencies];
  b. Virtual Asset related products or services [in particular, methods in which Anonymity-Enhanced Transactions can be conducted];
  c. Virtual Asset related business and professional practices; and
  d. technologies associated with VA Activities.