Crypto ATM / kiosk operator in Liberia

Act of the Legislature to Amend and Restate the Act Adopting a New Anti-Money Laundering and Countering the Financing of Terrorism Act of 2012 (AML/CFT Act of 2012, as amended): This is the primary legislation governing AML/CFT in Liberia. It establishes the legal framework for identifying, reporting, and prosecuting money laundering and terrorist financing. While it might not explicitly mention "virtual assets" or "VASPs" by name in its original form, its broad definitions of "funds," "financial institutions," and "designated non-financial businesses and professions" (DNFBPs) are often interpreted to cover virtual asset activities.

Financial Intelligence Unit of Liberia (FIUL) Act: This act establishes the FIUL as the central agency for receiving, analyzing, and disseminating suspicious transaction reports (STRs) and other financial intelligence.

Registration/Licensing: While specific VASP regulations in Liberia are evolving, the FATF recommendations require VASPs to be licensed or registered.

Customer Due Diligence (CDD) & Enhanced Due Diligence (EDD): VASPs must conduct CDD on all customers, including identifying and verifying the identity of the customer and beneficial owners. EDD is required for high-risk customers or transactions.

Record-Keeping: Maintain records of all transactions and customer information for a prescribed period.

Transaction Monitoring: Implement systems to monitor transactions for suspicious activity.

Suspicious Transaction Reporting (STRs): Report any suspicious transactions or activities, including those related to sanctioned entities or geographic areas, to the FIUL.

Risk-Based Approach: Implement a risk-based approach to AML/CFT, allocating resources proportionally to the identified risks.

Sanctions Compliance: Implement robust systems and controls to ensure compliance with UN, OFAC, and EU sanctions lists, including screening customers and transactions.

Continuous Screening: Implement ongoing screening of all customers, beneficial owners, and associated parties against up-to-date UN, OFAC, and EU sanctions lists.

Compliance Requirement for VASPs: VASPs must screen all their customers and transactions against the UN Consolidated Sanctions List (e.g., ISIL (Da'esh) & Al-Qaida Sanctions List, DPRK Sanctions List, etc.) to identify any sanctioned parties or activities.

United Nations (UN) Security Council Sanctions: These are universally binding on UN member states, including Liberia. UN sanctions lists target individuals, entities, and regimes involved in terrorism, proliferation of weapons of mass destruction, and other threats to international peace and security.

U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) Sanctions: While OFAC sanctions are primarily U.S. law, their extraterritorial reach (especially through the U.S. financial system) means that any VASP or financial institution anywhere in the world that engages in transactions involving a U.S. person, U.S. dollar, or U.S. technology must comply. Non-compliance can lead to severe penalties and loss of access to the U.S. financial system.

European Union (EU) Sanctions: EU sanctions are binding on persons and entities within EU jurisdiction, but like OFAC, they have a significant global impact due to the EU's economic power.

VASP Compliance Requirements: