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Acams CCAS Exam - Topic 2 Question 16 Discussion
Topic #: 2
An analyst at a virtual asset service provider (VASP) that white-labels its exchange solution to other cross-border VASPs is developing a VASP onboarding procedure. Under Financial Action Task Force Recommendation 13, which CDD practices should be applied to such relationships? (Select Three.)
FATF Recommendation 13 (Correspondent Banking and Similar Relationships) and its application to VASP--VASP relationships require enhanced due diligence before onboarding. This is because such arrangements carry elevated ML/TF risk, especially in cross-border settings.
Required CDD practices include:
Assess the nature and purpose of the VASP relationship (C): Understand why the relationship is being established and the expected services/products.
Obtain approval from senior management (D): Senior management oversight ensures risk is accepted at the appropriate governance level.
Assess the VASP's supervision and if a license/registration is needed (E): Confirm regulatory oversight, licensing, and compliance with AML/CFT obligations.
Options A and B are not core FATF requirements for CDD in this context --- local authority approval may be a domestic regulatory requirement in some countries, but not a FATF baseline, and profitability assessment is a business decision, not an AML measure.
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