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Certified Cryptoasset Anti-Financial Crime Specialistination Questions 36–40 (page: 9)

Updated On: 10-Feb-2026

According to the Financial Action Task Force report, "Virtual Assets Red Flag Indicators", which activity is a red flag related to anonymity?

  1. Executing multiple high-value transactions after a period of inactivity from the client
  2. Engaging in abnormal transactional activity of virtual assets cashed out at exchanges from peer-to- peer hosted wallets with no logical business explanation
  3. Making frequent transfers in a certain period of time (e.g., a day, a week, a month) to the same virtual asset account with a well-known virtual asset service provider
  4. Conducting Bitcoin-fiat currency exchanges at a potential loss

Answer(s): B

Explanation:

Red flags related to anonymity include transactions where virtual assets are cashed out at exchanges from peer-to-peer hosted wallets with no clear business rationale. Such behavior indicates attempts to obscure the origin or destination of funds, characteristic of laundering activities.

Executing high-value transactions after inactivity (A) or frequent transfers to known VASPs (C) may be suspicious but are less directly linked to anonymity. Exchanging at a loss (D) is a different type of red flag.

FATF's red flag indicators list (2021) highlights (B) as a key sign of anonymity-related risk.



Which operational risk mitigation practice by virtual asset service providers (VASPs) is most effective when considering their relationships with other VASPs?

  1. Having no requirement to establish a correspondent relationship and build a risk assessment framework among other cryptoasset exchanges prior to transferring for or on behalf of another person
  2. Developing cross-border correspondent relationships with cryptoasset exchanges in jurisdictions that have weak or non-existent anti-money laundering (AML) regulation or supervision
  3. Assigning all such relationships as high risk and conducting enhanced due diligence on all of them
  4. Gathering sufficient information on the counterpart VASP to determine the quality of the supervision it receives for transactional activities

Answer(s): D

Explanation:

Effective risk mitigation requires VASPs to obtain sufficient information about counterpart VASPs to assess the quality of their regulatory supervision and controls. This helps determine the risk of transactions and build a risk-based framework for correspondent relationships.

Having no requirements (A) or engaging with poorly regulated jurisdictions (B) increases risk. Blanket high-risk classification (C) without proper assessment is inefficient.

FATF Recommendation 15 and DFSA guidance emphasize due diligence on counterparties as a critical control.



Which is the discipline of risk management related to the risk of algorithms, machine learning, and artificial intelligence within the transaction monitoring and screening software that a virtual asset service provider acquires from a vendor?

  1. Vendor risk management
  2. IT security risk management
  3. Operational risk management
  4. Model risk management

Answer(s): D

Explanation:

Model risk management is the discipline focused on managing risks arising from the use of models, including those based on algorithms, machine learning, and AI in transaction monitoring and screening software.

Vendor risk management (A) covers third-party risks but not specifically model risks. IT security risk management (B) focuses on cybersecurity. Operational risk management (C) covers process and people risks but model risk management specifically addresses model validity, reliability, and performance.

DFSA and global AML frameworks highlight the need for strong model risk governance to ensure accurate detection and compliance.



Which scenario most likely indicates potential active involvement of a customer in virtual asset related scam activities?

  1. Indirect receiving from a scam cluster
  2. Indirect sending to a scam cluster
  3. Direct sending to a scam cluster
  4. Direct receiving from a scam cluster

Answer(s): C

Explanation:

Direct sending to a scam cluster indicates active involvement by the customer in potentially transferring funds associated with fraudulent activities. Sending funds directly to known scam addresses is a strong indicator of complicity or direct engagement.

Indirect flows (A and B) could be less conclusive, and direct receiving (D) may indicate victimhood rather than active involvement.

AML typologies and DFSA guidance identify direct outgoing transactions to scam clusters as significant red flags.



A suspicious activity report was filed in the EU for a local company account that held funds generated by the sale of product coupons. A review of the account highlighted a login from an unconnected IP address. Despite repeated requests, the customer failed to provide information on the origins of the funds.
Which is the main red flag here?

  1. Virtual asset service providers outside of the EU are being relied upon.
  2. Funds are generated by the sale of coupons which are connected to a physical product.
  3. There is a failure to cooperate with the source of funds requests.
  4. An IP address is being used that is not previously connected to that customer.

Answer(s): C

Explanation:

The main red flag is the customer's failure to cooperate with requests to provide information on the origin of funds, which undermines transparency and raises suspicion regarding the legitimacy of the funds.

While an unconnected IP address (D) is suspicious, non-cooperation (C) is a stronger indicator of potential money laundering.



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