procedures as specified in the notification. In this regard, Bitazza insufficiently provided the system to ensure that Bitazza could know and verify the true identity of its customers, including acquiring

Bitazza could know and verify the true identity of its customers, including acquiring adequate information for customers’ risk assessment. DAB Act S.94 in conjunction with 30 Settlement Committee Meeting

from DAOLS’ failure to exercise due care and diligence in protecting the interests of the bondholders, including failing to verify existing encumbrances on the condominium units serving as collateral