Acams Certified Cryptoasset Anti-Financial Crime Specialist Examination CCAS Exam Practice Test

Answer : B

DFSA AML Module requires the Board to approve and oversee the firm's business-wide risk assessment, ensuring accountability at the highest governance level.

Answer : B, D

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).

Answer : C

Decentralized exchanges lack a central counterparty responsible for AML compliance, making it difficult to enforce KYC/CDD, monitor transactions, or implement controls. This structural characteristic increases inherent AML risk compared to centralized exchanges, which have accountable operators.

Transaction cost (A), validator nodes (B), or asset types (D) are less impactful in the compliance risk rating.

Answer : C

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.

Answer : D

Funds moving through multiple intermediary wallets before arriving at the client's wallet indicate layering techniques used to obscure the source of funds, a classic money laundering tactic.

Transferring funds quickly (A) or declaring wealth (B) are less definitive indicators. An untraceable IP (C) raises concerns but is less conclusive than complex transactional layering.

Answer : C

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.

Answer : A

The FinCEN 2019 guidance clarifies that money transmitters include entities that exchange digital tokens or convertible virtual currencies as part of their business activities. This includes exchanges and platforms that transfer virtual currencies.

Providing infrastructure services (B), operating clearance systems solely among regulated institutions (C), or acting as payment processors for goods/services (D) without handling value transfer do not fall under the money transmitter definition per this guidance.