Centralized exchange in Liberia

No specific custodial license for digital assets currently exists. Any entity in Liberia offering digital asset custody services would likely operate in a regulatory gray area or might be indirectly subject to general financial services licensing if its activities are deemed to fall under existing financial institution definitions (e.g., as a payment service provider or financial intermediary), but this would not be crypto-specific.

No specific rules exist for the segregation of client digital assets. In traditional finance, robust segregation rules protect client funds from institutional insolvency. Without a specific framework for digital assets, such rules are absent.

No specific mandates for cold storage or other technical security requirements for digital asset custody. This level of technical detail in regulation is characteristic of more mature crypto regulatory frameworks, which Liberia does not yet possess.

No specific definition of a "qualified custodian" for digital assets. This term typically arises in jurisdictions where registered investment advisors or other regulated entities are required to hold client assets with a "qualified custodian," usually a regulated bank or trust company meeting specific criteria.

VASP Compliance Requirements:

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.

No, not specifically for Virtual Assets (VAs) and Virtual Asset Service Providers (VASPs). The 2021 FATF MER explicitly states that Liberia "has not yet assessed its money laundering and terrorist financing risks relating to virtual assets and VASPs, and has not yet put in place the necessary legal or regulatory framework for VAs and VASPs as required by Recommendation 15."

No specific category of VASPs is currently covered by AML/CTF obligations or Travel Rule requirements in Liberia, due to the lack of a comprehensive legal and regulatory framework for VAs/VASPs. The FATF MER highlights that Liberia has not identified or licensed any VASPs operating in its jurisdiction, nor has it applied AML/CTF requirements to them.

This means that the specific requirements of the Travel Rule (FATF Recommendation 16) for VASPs, which mandate the collection and transmission of originator and beneficiary information, have not been adopted into Liberian law or regulation.

FATF Mutual Evaluation Report of Liberia (October 2021):