ACAMS Virtual Assets and Cryptocurrency AML 3

Question 1

Which international body is responsible for setting the global AML/CFT standards that now explicitly cover virtual assets and VASPs?

Accepted Answer

The Financial Action Task Force (FATF)

Answer

The Financial Action Task Force (FATF) sets the global AML/CFT standards, including the 2019 updates to its Recommendations and Guidance that brought virtual assets and VASPs under the same compliance framework as traditional financial institutions.

Question 2

A VASP receives a large transfer of Bitcoin from a wallet address that blockchain analytics tools flag as associated with a darknet marketplace. What is the compliance officer's most appropriate immediate action?

Accepted Answer

Conduct enhanced due diligence, consider freezing the funds, and evaluate whether to file a SAR

Answer

When blockchain analytics flag a wallet as linked to illicit activity, the compliance officer must conduct enhanced due diligence, consider whether the funds should be frozen pending investigation, and determine if the suspicious activity warrants filing a SAR with FinCEN.

Question 3

What is 'transaction monitoring' in the context of a VASP's AML program, and what makes it uniquely challenging compared to traditional banking?

Accepted Answer

It involves watching blockchain public ledgers; the challenge is that pseudonymous addresses obscure beneficial ownership

Answer

Transaction monitoring for VASPs uses blockchain analytics to detect suspicious patterns on public ledgers, but the pseudonymous nature of wallet addresses — where owners are not inherently identifiable — makes it significantly harder to link activity to real-world individuals than in traditional banking.

Question 4

When must a U.S.-based cryptocurrency exchange file a Currency Transaction Report (CTR) under Bank Secrecy Act rules?

Accepted Answer

When a customer conducts a transaction or series of related transactions in cash or cash equivalents exceeding $10,000 in a single day

Answer

Under the BSA, MSBs including cryptocurrency exchanges must file a CTR when a customer conducts transactions in currency (or currency equivalents) exceeding $10,000 in a single day, whether or not the transactions involve cryptocurrency or fiat.

Question 5

Which of the following best describes 'on-chain analytics' as a tool for AML compliance in the cryptocurrency space?

Accepted Answer

A method of analyzing publicly recorded blockchain transaction data to identify suspicious patterns and trace fund flows

Answer

On-chain analytics involves examining the publicly available transaction data recorded on blockchain ledgers to identify patterns consistent with money laundering, cluster wallet addresses, attribute addresses to known entities, and trace illicit fund flows.

(ACAMS) Association of Certified Anti-Money Laundering Specialists Practice Test

(ACAMS) Association of Certified Anti-Money Laundering Specialists Practice Test

ACAMS Virtual Assets and Cryptocurrency AML 3