Page 50 - 《期货和衍生品行业监管动态》（2022年合集）

期货和衍生品行业监管动态

otherwise suspicious and ensuring that these are reported quickly to the
nominated officer for timely consideration

 where blockchain analytics solutions are deployed, ensuring that

compliance teams understand how these capabilities can be best used to identify

transactions linked to higher risk wallet addresses

 engage with public-private partnerships and private-private partnerships

to gather insights on the latest typologies and additional controls that might be

relevant and share their own best practice examples

Firms should also look for red flag indicators that suggest an increased risk of

sanctions evasion. These may include, but are not limited to:

 a customer who is resident in or conducting transactions to or from a

jurisdiction which is subject to sanctions, or which is on the UK’s High Risk
Third Countries list for anti-money laundering and counter-terrorist financing

purposes, or any jurisdiction you have identified as posing an increased risk of

illicit financial activity

 transactions to or from a wallet address associated with a sanctioned

entity, or a wallet address otherwise deemed to be high-risk, based on its

transaction history or that of associated addresses, or other factors

 transactions involving a cryptoasset exchange or custodian wallet

provider known to have poor customer due diligence procedures or which is

otherwise deemed high-risk

 the use of tools designed to obfuscate the location of the customer (eg an

IP address associated with a virtual private network or proxy) or the source of

cryptoassets (eg mixers and tumblers)

 other red flag indicators that are normally associated with money
laundering more broadly. In both situations, the aim of the illicit actor is to make

an illegal transaction seem legitimate

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