Management must consider a comprehensive set of features when evaluating virtual asset products and services, including:
Ability for other VASPs to utilize the service (A):This increases risk exposure as services may be used indirectly by unknown parties.
Ability to mingle funds within wider pools (B):Mixing services or pooled wallets increase anonymity and laundering risk.
Regulatory expectations (C):Management must ensure compliance with all applicable laws and guidelines.
Transaction volumes (D):High transaction volumes can increase operational risk and require enhanced monitoring.
The DFSA AML and COB Modules, as well as FATF guidance, stress that a risk-based approach requires consideration of all these features in product/service risk assessments.
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