CCA Anti-Money Laundering & Financial Crime in Crypto

Question 1

Under the Bank Secrecy Act (BSA), U.S. cryptocurrency exchanges registered as Money Services Businesses (MSBs) are required to file a Currency Transaction Report (CTR) for cash transactions exceeding what threshold?

Accepted Answer

$10,000

Answer

$5,000

Answer

$25,000

Answer

$3,000

Question 2

Which blockchain analytics technique do CCA-certified auditors primarily use to identify cryptocurrency wallets associated with sanctioned entities?

Accepted Answer

Cluster analysis to group wallets by common ownership indicators and cross-reference against OFAC SDN addresses

Answer

Social media monitoring for wallet address disclosures

Answer

IP address logging from exchange servers

Answer

Review of mining pool payout records

Question 3

A cryptocurrency transaction shows funds moving through a chain of 15 intermediate wallets before reaching a final destination. This pattern is most consistent with which money laundering stage?

Accepted Answer

Layering — obscuring the trail between illicit funds and their ultimate destination

Answer

Placement — introducing illicit funds into the financial system

Answer

Integration — reintroducing cleaned funds into the legitimate economy

Answer

Structuring — breaking transactions into small amounts to avoid reporting

Question 4

What is a 'mixer' or 'tumbler' in the context of cryptocurrency AML compliance?

Accepted Answer

A service that pools and redistributes cryptocurrency to obscure the link between sending and receiving addresses

Answer

A tool for converting cryptocurrency to fiat currency

Answer

A DeFi protocol for earning yield on idle crypto

Answer

A hardware device for secure private key storage

Question 5

Under FATF Recommendation 15 and its interpretive note for Virtual Assets, which type of entity is defined as a Virtual Asset Service Provider (VASP) subject to AML obligations?

Accepted Answer

Any natural or legal person that conducts one or more of the specified VA activities (exchange, transfer, custody, etc.) as a business for another person

Answer

Only centralized cryptocurrency exchanges with more than 10,000 users

Answer

Only entities that hold a state money transmitter license

Answer

Only DeFi protocols with more than $1B in total value locked

Question 6

A CCA auditor reviewing a crypto exchange's AML program finds that the exchange does not screen customers against the OFAC Specially Designated Nationals (SDN) list. What is the potential consequence?

Accepted Answer

Civil and criminal penalties under the International Emergency Economic Powers Act (IEEPA) and OFAC regulations

Answer

Revocation of the exchange's MSB registration only

Answer

SEC enforcement action for securities violations

Answer

Loss of banking relationships only