Remote VASP serving residents in Liberia

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.

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.

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.

VASP Compliance Requirements:

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.

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

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

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."

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.

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.

FATF Mutual Evaluation Report of Liberia (October 2021):

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.

Segregation of Client Assets Rules:

No specific insurance or bonding requirements for digital asset custodians. Traditional financial institutions might have deposit insurance (e.g., through the Liberia Deposit Insurance Corporation, LDIC) or capital requirements, but these do not extend to digital asset holdings.

Cold Storage Mandates: