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I still don't get the main concept here. Is it an actual risk factor or a fraudulent related risk factor?.
When it comes to the actual risk factor, I am not sure of how the C-RAM can work effectively due to the volatile concept of digital Currencies, though it can be minimized to the list minimum.
Let's see how far they will go in the fraudulent factor.
RE: The IMF Introduces a Tool for Assessing Cryptocurrency Risks