Money laundering risk increases if the business operates in or near high-risk jurisdictions (D) or regions associated with narcotics production (C), as these are common sources of illicit funds.
An increase in volume and users (A) or supporting various cryptoassets (B) alone does not necessarily increase ML risk. Recent licensing (E) may indicate regulatory compliance, potentially lowering risk.

Indirect exposure refers to connections through one or more hops to illicit addresses. This requires robust transaction chain analysis to detect hidden ML/TF risk.

Direct sending to a scam cluster indicates active involvement by the customer in potentially transferring funds associated with fraudulent activities. Sending funds directly to known scam addresses is a strong indicator of complicity or direct engagement.
Indirect flows (A and B) could be less conclusive, and direct receiving (D) may indicate victimhood rather than active involvement.
AML typologies and DFSA guidance identify direct outgoing transactions to scam clusters as significant red flags.

An effective AML CDD program must include:
Staff training on gathering CDD (A)
Maintaining complete information to support risk profiling (B)
Procedures to address situations where the customer's true identity is unclear or questionable (F) Annual client reviews (D) and IP address monitoring (E) may be part of broader AML controls but are not fundamental CDD requirements. Maintaining a list of high-risk virtual assets (C) is important but relates more to product risk management than direct CDD.

Red flags related to anonymity include transactions where virtual assets are cashed out at exchanges from peer-to-peer hosted wallets with no clear business rationale. Such behavior indicates attempts to obscure the origin or destination of funds, characteristic of laundering activities.
Executing high-value transactions after inactivity (A) or frequent transfers to known VASPs (C) may be suspicious but are less directly linked to anonymity. Exchanging at a loss (D) is a different type of red flag.
FATF's red flag indicators list (2021) highlights (B) as a key sign of anonymity-related risk.