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

The BSA CTR threshold is $10,000 for cash transactions, and FinCEN has confirmed this applies to MSBs including cryptocurrency exchanges that handle cash equivalent transactions.

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

Cluster analysis groups blockchain addresses believed to be controlled by the same entity based on transaction patterns, and matching these clusters against OFAC's Specially Designated Nationals list identifies potential sanctions violations.

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

Chaining transactions through many intermediate wallets is a classic layering technique designed to create distance between the source of illicit funds and their final destination, complicating blockchain tracing.

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

Mixers pool funds from multiple users and redistribute equivalent amounts to output addresses, deliberately breaking the on-chain transaction trail to prevent blockchain analytics from tracing the original source.

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

FATF defines VASPs broadly as any entity conducting virtual asset activities (exchange, transfer, safekeeping, administration, or financial services for token offerings) as a business on behalf of others, regardless of size.

(CCA) Certified Cryptocurrency Auditor Practice Test

(CCA) Certified Cryptocurrency Auditor Practice Test

CCA Anti-Money Laundering & Financial Crime in Crypto