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When determining highest-risk customers under a risk-based approach, firms must consider transaction patterns, jurisdictions, counterparties, and destinations: B: Large deposits by a student, rapidly converting to crypto and sending to another VASP, suggest potential layering and third-party funding risk. D: Daily inbound transfers from a foreign VASP to a private (unhosted) wallet indicate consistent high-risk exposure - especially cross-border transactions involving unregulated or weakly regulated jurisdictions. While VPN use (A) can be a red flag, on its own it is lower risk than significant suspicious fund flows. Paying suppliers in crypto (C) can be legitimate for businesses. A large donation to a charity (E) could be flagged depending on jurisdiction and cause, but is generally less inherently suspicious than B and D unless linked to high-risk entities. FATF, DFSA, and FSRA AML rules stress that ongoing monitoring should identify these high-frequency, high-value, cross-border crypto flows as priority for Enhanced Due Diligence (EDD) and possible Suspicious Transaction Reports (STRs).
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