Cryptocurrency AML and Compliance Flashcards

Under FinCEN's 2019 guidance, a business that accepts and transmits convertible virtual currency (CVC) for customers is generally classified as what?

Answer: A money transmitter (MSB)

FinCEN treats CVC exchangers and administrators that accept and transmit value as money transmitters subject to BSA rules.

What is the U.S. BSA threshold at which the Recordkeeping and Travel Rule applies to transmittals of funds?

Answer: $3,000

31 CFR 1010.410(f) requires originator and beneficiary information to travel with transmittals of $3,000 or more.

The FATF recommends that Travel Rule obligations for virtual asset transfers apply above what de minimis threshold?

Answer: USD/EUR 1,000

FATF's Interpretive Note to Recommendation 15 sets a USD/EUR 1,000 de minimis threshold for VA transfers.

Which FATF Recommendation specifically extends AML/CFT obligations to virtual assets and VASPs?

Answer: Recommendation 15

Recommendation 15 on new technologies was amended in 2018-2019 to cover virtual assets and VASPs.

Within how many days of establishment must a new money services business register with FinCEN?

Answer: 180 days

MSBs must register with FinCEN within 180 days of being established and renew every two years.

What is the 'sunrise issue' in Travel Rule compliance?

Answer: Uneven adoption of the Travel Rule across jurisdictions, leaving VASPs unable to exchange data with non-compliant counterparts

The sunrise issue refers to staggered implementation across countries, so some counterparty VASPs are not yet obligated to send or receive Travel Rule data.

Which of the following is a messaging protocol developed to help VASPs exchange Travel Rule data?

Answer: TRISA

TRISA (Travel Rule Information Sharing Architecture) is one of several open protocols built for VASP-to-VASP Travel Rule messaging.