GDF Virtual Asset Due Diligence Questionnaire
The AML / KYC Working Group has developed an Anti-Money Laundering Due Diligence Questionnaire for Virtual Asset Service Providers (VASPs).The questionnaire has been designed to provide an overview of a VASP’s anti-money laundering policies and practices. It may be used by VASPs onboarding counterparty VASPs, or Financial Institutions (Banks) onboarding VASPs.
The questionnaire is intended to be used as part of the due diligence and risk management programme of the DDQ Issuing Entity (the entity performing the due diligence). The DDQ remains neutral on risk assessment or scoring methodology to permit the DDQ Issuing Entity to assess responses according to internal risk appetite. DDQ Issuing Entities may amend this GDF VADDQ to suit their specific requirements, as long as it remains in accordance with the license conditions (to be approved by the GDF Board).
This work will sit under and be governed by the GDF Open Standards Council, a council chaired by a GDF board director, and comprising all the (open-source) working group co-chairs, planned to be launched in Q2. Once it is legally novated, the Open Standards Council is accountable to the GDF Board (not to the GDF Advisory Council) to ensure its independence and to avoid membership concentration risks or vested interests. The Open Standards Council is exploring licensing options that ensures that community participants are able to distribute, remix, adapt and build upon the GDF VADDQ in any medium or format, and to develop derivative works as long as these changes are disclosed to the Open Standards Council.
The GDF VADDQ is based upon the work of the Wolfsberg Group and GDF acknowledges and thanks the Wolfsberg Group for permitting the use of Correspondent Banking Due Diligence Questionnaire upon which this VA Due DIligence Questionnaire is based. GDF also extends thanks to Malcolm Wright, former Co-Lead of the AML Working Group and former Regulatory Affairs Director, Asia for driving the concept and execution of the VA Due Diligence Questionnaire, as well as the dedicated team of AML professionals from across the globe who have spend considerable time and effort in supporting the development and delivery over the past two years.
