CCI Legal Compliance 2

Question 1

Under FinCEN rules, a money services business (MSB) must file a Suspicious Activity Report for suspicious transactions involving at least what amount?

Accepted Answer

$2,000

Answer

31 CFR 1022.320 sets the MSB SAR threshold at $2,000, lower than the $5,000 threshold for banks.

Question 2

How many calendar days does a financial institution generally have to file a SAR after first detecting facts that may justify a filing?

Accepted Answer

30 days

Answer

A SAR is due within 30 days of initial detection, extendable to 60 days if no suspect has been identified.

Question 3

Which federal statute specifically criminalizes operating an unlicensed money transmitting business, often charged against crypto mixer operators?

Accepted Answer

18 U.S.C. § 1960

Answer

18 U.S.C. § 1960 prohibits unlicensed money transmitting and was charged in cases such as Bitcoin Fog and Helix.

Question 4

In United States v. Gratkowski (5th Cir. 2020), the court held that a user's records held by Coinbase were:

Accepted Answer

Not protected because of the third-party doctrine

Answer

The court found no reasonable expectation of privacy in exchange records voluntarily shared with a third party.

Question 5

A crypto exchange employee tells a customer that a SAR was filed on their account. Which legal rule has been violated?

Accepted Answer

SAR confidentiality (anti-tipping-off) rule

Answer

Federal law prohibits disclosing a SAR or any information that would reveal its existence.

CCI - Certified Cryptocurrency Investigator Practice Test

CCI - Certified Cryptocurrency Investigator Practice Test

CCI Legal Compliance 2