The client, a crypto-currency exchange, has requested Avantage Reply to assist with an ongoing project around fraud risk. As the regulation around virtual asset service providers is not yet mature, the measurement of new and non-traditional operational risks is not an easy exercise. In fact, several players in the industry have recently found themselves being vehicles for the continuation of various financial crimes, including fraud. In the client landscape, scammers and individuals with malicious intentions have exploited the weaknesses of decentralized finance (DeFi) and have misappropriated even millions of dollars from their victims through first party or third party external fraud.