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I find nothing particularly wrong with the principles of this regulation. The stipulations are apparently for the protection and smooth business experience of every DLT provider's customers and even the DLT providers themselves.
The terms are general, though. So we still do not know the specific steps and policies that would be implemented by each DLT provider in line with them. For example, under this:
I have these particular probing questions, among others:
The terms are general, though. So we still do not know the specific steps and policies that would be implemented by each DLT provider in line with them. For example, under this:
Quote
8. A DLT Provider must have systems in place to prevent, detect and disclose financial crime risks such as money laundering and terrorist financing.
DLT Providers must adequately apply anti-money laundering and counter terrorist financing preventive measures which are commensurate with their risks, and report suspicious transactions. DLT Providers need to be aware of the vulnerabilities of its products and services to financial crime risks and ensure that they implement measures to mitigate the risks.
DLT Providers need to comply with the Proceeds of Crime Act and any guidance issued by the GFSC.
DLT Providers must adequately apply anti-money laundering and counter terrorist financing preventive measures which are commensurate with their risks, and report suspicious transactions. DLT Providers need to be aware of the vulnerabilities of its products and services to financial crime risks and ensure that they implement measures to mitigate the risks.
DLT Providers need to comply with the Proceeds of Crime Act and any guidance issued by the GFSC.
I have these particular probing questions, among others:
- What specific "systems" are they talking about?
- What are these "preventive measures" that would be implemented under this specific principle?
- Are they going to be requiring KYC to each and every customer?
- What are covered under "suspicious transactions"?
- What steps are DLT Providers going to take upon the discovery of these "suspicious transactions"?
- Will there be immediate blocking of accounts and the like?
