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1. A useful article, and includes helpful pointers for AMLCOs with accounts in their organisation which may be linked to exchanges or crypto-users.

   However, it would also be worthwhile setting out the legitimate and useful reasons people hold crypto. This can include avoiding currency debasement, concealing assets from corrupt regimes, accessing lifesaving medicines which cannot be legally bought in their own country, paying for political opposition without being targeted, and as we have seen with Venezuela, fleeing as refugees with the ability to recover some wealth remotely. AMLCOs need to be aware of the legitimate reasons, so that explanations by customers can be considered rationally.

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