A compliance officer is conducting a customer risk review.

When determininghighest-risk customersunder 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 thesehigh-frequency, high-value, cross-border crypto flowsas priority for Enhanced Due Diligence (EDD) and possible Suspicious Transaction Reports (STRs).