9.3.1. Japan

289. Because most VASPs are new to AML/CFT regulation, common shortcomings can emerge based on a lack of awareness of requirements. For example, when it first started supervising VASPs in 2017, the Japanese FSA (JFSA) found consistent failings in quality of KYC/CDD and record keeping as well as a lack of regulatory understanding and expertise in key positions. Dialogue with the sector can be an important way to address these issues and present best practice. The JFSA has periodically reached out to VASPs through mainly the Japan Virtual and Crypto assets Exchange Association, SRO in Japan, to provide feedback on issues it is encountering and to stress the importance. Those explanatory sessions covers topics such as, but not limited to: scope of AML Risk Assessment, recent cases of suspicious transaction reporting in VASP sector, terrorist Financing, the revised National Risk Assessment, AML Internal Audit, Recent AML Law revision/e-KYC, Travel Rule - INR.15 (7b) revision and FATF 12 month review report. JFSA has found its initiatives so far have worked to enhance industry's awareness and its AML/CFT controls. In addition to the above, JFSA participated in several domestic and international seminars held by private sector stakeholders, industry associations or technology vendors, to cover VA involving AML topics for a wider audience.

9.3.2. United States