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D. Risk Category 4: Customer VAs

1.
Customer authentication standard: To reduce the risk of any customer account compromises, VASPs are expected to implement robust customer authentication, including but not limited to—
 
a.strong multifactor authentication;
b.prohibition of instant messaging verification for high-risk operations;
c.risk-based authentication challenges and biometric authentication where appropriate; and
d.suspicious login detection and alerting.
 
2.
Withdrawal control standard: To limit potential losses from compromised accounts through structured withdrawal controls, VASPs are expected to implement comprehensive withdrawal controls, including—
 
a.tiered withdrawal limits;
b.cooling periods for large transactions;
c.verification for high-value withdrawals outside of prescribed limits and/or ‘bands’;
d.verification for critical transactions;
e.behavioural analysis to detect anomalous withdrawal patterns; and
f.graduated approval requirements based on transaction value.
 
3.
User education standard: To reduce customer vulnerability to social engineering and other attacks through improved awareness, VASPs are expected to implement comprehensive user education programmes, including but not limited to—
 
a.security best practices;
b.common attack vector awareness and secure account management guidance; and
c.regular security notifications.
 
4.
VA Wallet concentration risk standard: To reduce the risk of concentration of Client VAs in a single or small number of VA Wallets, VASPs are expected to implement controls for the safe diversification of Client VAs across VA Wallets, including but not limited to—
 
a.cold storage VA Wallets;
b.VARA Licensed VASPs providing Custody Services; and
c.physical distribution of servers storing information through which VA Wallets can be accessed and/or controlled.