Appoint an MLRO with at least two years of AML/CFT experience who is fit and proper, reviewed annually, responsible for AML/CFT training, policies, risk assessments, suspicious transaction monitoring and reporting, corrective action, and quarterly Board reports on AML/CFT effectiveness including a summary of anonymity-enhanced transactions and clients, available to VARA; delegated tasks remain the MLRO's responsibility and the MLRO may combine non-conflicting non-client-facing roles.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.