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ACAMS Certified Cryptoasset Anti-Financial Crime Specialist Examination Sample Questions (Q77-Q82):
NEW QUESTION # 77
Which is the first action a virtual asset service provider (VASP) should take when it finds out that its customers are engaging in virtual asset (VA) transfers related to unhosted wallets and peer-to-peer (P2P) transactions?
- A. Collect and assess the data on transactions related to P2P or unhosted wallets to determine if it is within its risk appetite.
- B. Freeze accounts with records of transactions related to P2P transactions or unhosted wallets.
- C. Enhance existing risk-based control framework to account for specific risks posed by transactions related to P2P or unhosted wallets.
- D. Allow VA transfers related P2P or unhosted wallets below 1,000 USD or the equivalent amount in local currency, or per defined thresholds in local regulations.
Answer: A
Explanation:
Upon identifying customer engagement with unhosted wallets or P2P transfers, the first step a VASP should take is to collect and assess data on such transactions. This assessment helps determine if these activities fall within the firm's risk appetite and what enhanced controls or actions may be needed.
Immediate account freezing (B) is not the first step without assessment; neither is allowing transfers (A) without risk consideration. Enhancing risk frameworks (D) is important but follows from an initial data-driven risk assessment.
Relevant guidance:
FATF Recommendations and DFSA AML Module require VASPs to maintain a risk-based approach that begins with data collection and risk assessment on unhosted wallet transactions.
The DFSA's 2023 Dear MLRO letters and thematic reviews stress proportionality and evidence-based responses rather than immediate punitive measures.
Enhanced due diligence (EDD) and risk mitigation measures, including potentially freezing accounts, come after assessment of the risk level【AML/VER25/05-24: Sections 4.1, 6.4, 13; 20230406Dear_MLRO_Letter_re_IEMS.pdf】.
Hence, C is the appropriate first action.
NEW QUESTION # 78
A politically exposed person (PEP) opens a crypto account. What is the required action?
- A. Apply EDD and senior management approval.
- B. Request a travel rule exemption.
- C. Decline onboarding.
- D. Treat as standard customer.
Answer: A
Explanation:
PEPs require enhanced scrutiny under FATF Recommendation 12, including senior management approval and source of funds verification.
NEW QUESTION # 79
A compliance officer is conducting an AML risk assessment of two different operating models: a centralized cryptoasset exchange and a decentralized cryptoasset exchange. Which key difference causes the compliance officer to risk-rate the decentralized exchange higher than the centralized exchange?
- A. The lack of a central counterparty
- B. The cost of each transaction
- C. The supported asset types
- D. The number of validator nodes
Answer: A
Explanation:
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.
NEW QUESTION # 80
An exchange uses blockchain analytics to identify high-risk wallet clusters. This is an example of:
- A. KYC
- B. On-chain forensic analysis
- C. Custodial control
- D. Transaction screening
Answer: B
Explanation:
On-chain forensic analysis uses blockchain data to detect illicit wallet patterns and cluster associations.
NEW QUESTION # 81
Which risk category covers threats from ransomware actors demanding payment in cryptoassets?
- A. Liquidity risk
- B. Counterparty risk
- C. Operational risk
- D. Cyber-enabled financial crime risk
Answer: D
Explanation:
Ransomware schemes are categorized as cyber-enabled financial crimes. AML/CFT frameworks require that such risks be assessed and mitigated through blockchain analytics, sanctions screening, and transaction monitoring for known ransomware wallet addresses.
NEW QUESTION # 82
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