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ACAMS CCAS Exam
Certified Cryptoasset Anti-Financial Crime Specialistination (Page 4 )

Updated On: 7-Feb-2026
Page 4 of 21
PDF with 100 Questions

An analyst at a virtual asset service provider (VASP) that white-labels its exchange solution to other cross-border VASPs is developing a VASP onboarding procedure. Under Financial Action Task Force Recommendation 13, which CDD practices should be applied to such relationships? (Select Three.)

  1. Obtain approval from the local supervisory authority
  2. Assess the profitability of the VASP relationship
  3. Assess the nature and purpose of the VASP relationship
  4. Obtain approval from senior management
  5. Assess the VASP's supervision and if a license/registration is needed

Answer(s): C,D,E

Explanation:

FATF Recommendation 13 (Correspondent Banking and Similar Relationships) and its application to VASP­VASP relationships require enhanced due diligence before onboarding. This is because such arrangements carry elevated ML/TF risk, especially in cross-border settings.

Required CDD practices include:

Assess the nature and purpose of the VASP relationship (C): Understand why the relationship is being established and the expected services/products.

Obtain approval from senior management (D): Senior management oversight ensures risk is accepted at the appropriate governance level.

Assess the VASP's supervision and if a license/registration is needed (E): Confirm regulatory oversight, licensing, and compliance with AML/CFT obligations.

Options A and B are not core FATF requirements for CDD in this context -- local authority approval may be a domestic regulatory requirement in some countries, but not a FATF baseline, and profitability assessment is a business decision, not an AML measure.



A compliance officer is conducting a customer risk review.
Which statements represent the highest level of customer risk? (Select Two.)

  1. A customer who uses a virtual private network (VPN) connection to access the customer's account
  2. A student customer depositing 15,000 USD over a period of a month, using the funds to purchase cryptoassets that are sent to another virtual asset service provider
  3. A business customer opting to pay suppliers in cryptoassets
  4. A customer receiving cryptoassets daily from another virtual asset service provider located in a foreign jurisdiction which are then sent to a private wallet
  5. A customer located in a foreign country donating 10,000 USD worth of cryptoassets to a charity for veterans in the US

Answer(s): B,D

Explanation:

When determining highest-risk customers under a risk-based approach, firms must consider transaction patterns, jurisdictions, counterparties, and destinations:

B: Large deposits by a student, rapidly converting to crypto and sending to another VASP, suggest potential layering and third-party funding risk.

D: Daily inbound transfers from a foreign VASP to a private (unhosted) wallet indicate consistent high-risk exposure -- especially cross-border transactions involving unregulated or weakly regulated jurisdictions.

While VPN use (A) can be a red flag, on its own it is lower risk than significant suspicious fund flows. Paying suppliers in crypto (C) can be legitimate for businesses. A large donation to a charity (E) could be flagged depending on jurisdiction and cause, but is generally less inherently suspicious than B and D unless linked to high-risk entities.

FATF, DFSA, and FSRA AML rules stress that ongoing monitoring should identify these high-frequency, high-value, cross-border crypto flows as priority for Enhanced Due Diligence (EDD) and possible Suspicious Transaction Reports (STRs).



Which token type should be considered as carrying the highest risk when assessing the AML risks related to the customer's source of funds?

  1. Privacy
  2. Stablecoin
  3. Platform
  4. Security

Answer(s): A

Explanation:

Privacy tokens are specifically designed to obfuscate transaction details such as sender, recipient, and amounts, making them inherently high risk for money laundering and terrorist financing. Their anonymity-enhanced features pose significant challenges to AML efforts.

Stablecoins (B), platform tokens (C), and security tokens (D) have varying risk profiles but generally provide more transparency or are subject to regulatory frameworks, reducing inherent AML risk compared to privacy tokens.

FATF and DFSA AML frameworks highlight privacy tokens as a priority for enhanced due diligence and risk mitigation due to their abuse potential.



A compliance officer Is assigned a group of customers.
Which action should the officer fake to determine the appropriate level of customer due diligence apply to each customer?

  1. Assess only the money laundering risks posed by customer location
  2. Examine what Threshold for occasional transactions can be set for each customer.
  3. Implement the same COD measures for each customer.
  4. Take into account all risk variables such as me purpose of the account or relationship

Answer(s): D

Explanation:

A risk-based approach to customer due diligence requires considering all relevant risk factors including customer profile, the nature and purpose of the account or relationship, geographic risks, transaction patterns, and other relevant factors. This ensures that CDD intensity is commensurate with assessed risk.

Assessing only location (A) or transaction thresholds (B) is insufficient alone. Applying uniform CDD measures (C) contradicts the risk-based approach advocated by FATF and DFSA regulations.

DFSA AML guidance explicitly requires comprehensive risk assessment considering multiple variables to determine appropriate due diligence levels.



According to me Financial Action Task Force's (FATF's> definition of virtual asset service provider (VASP), for which activity is an entity required to be licensee or registered as a VASP in the jurisdiction(s) where they are created?

  1. Cryptocurrency mining operations
  2. Safekeeping and/or administration of virtual assets and exchange between one or more forms of virtual assets
  3. Operating blockchain nodes
  4. Virtual money service businesses

Answer(s): B

Explanation:

FATF defines VASPs as entities that conduct certain specified activities involving virtual assets. Licensing or registration as a VASP is required primarily for entities engaged in activities such as safekeeping and/or administration of virtual assets or conducting exchanges between one or more forms of virtual assets.

Cryptocurrency mining operations (A) and operating blockchain nodes (C) are generally excluded from the VASP definition because they do not involve handling customer funds or providing financial services. Virtual money service businesses (D) is a broader term that may include VASPs but not all such businesses fall under VASP regulations unless they meet the activity criteria.

This aligns with the DFSA AML Module and FATF Recommendation 15, which regulate entities providing virtual asset custody or exchange services to customers and require them to be licensed or registered.



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