CCI Cryptocurrency AML and Compliance 2

Question 1

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

Accepted Answer

A money transmitter (MSB)

Answer

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

Question 2

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

Accepted Answer

$3,000

Answer

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

Question 3

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

Accepted Answer

USD/EUR 1,000

Answer

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

Question 4

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

Accepted Answer

Recommendation 15

Answer

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

Question 5

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

Accepted Answer

180 days

Answer

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

CCI - Certified Cryptocurrency Investigator Practice Test