Free Practice Questions for ACAMS CCAS Exam

Upon identifying customer engagement with unhosted wallets or P2P transfers, the first step a VASP should take is tocollect and assess dataon 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,Cis the appropriate first action.

The most critical information enabling FIUs to address anonymity risks is data linking a virtual address to the real-world identity of its owner. Without this association, blockchain addresses remain pseudonymous, hindering effective AML efforts.

While transaction timing (A), identity of receiver (B), and transaction-to-address mapping (C) are useful, ownership linkage (D) is essential to break anonymity.

FATF and DFSA guidance prioritize obtaining ownership information through KYC and intelligence sharing.

Monero is a privacy-focused blockchain designed with built-in features like ring signatures, stealth addresses, and confidential transactions to obfuscate sender, receiver, and transaction amounts, making tracing difficult.

Cardano, Polygon, and Ethereum are not designed primarily with these privacy features and have publicly traceable ledgers, although privacy solutions may be layered on.

Stablecoins aim to maintain value stability by pegging to assets like fiat currency or commodities. Regulators stress monitoring stablecoin reserve transparency to prevent misuse for layering illicit funds.

The FATF Travel Rule requires Virtual Asset Service Providers to share originator and beneficiary information for virtual asset transfers exceeding a certain threshold. Its purpose is to mitigate ML/TF risks by increasing transparency and enabling authorities to trace the movement of funds across institutions and jurisdictions.

It does not aim to slow transactions (B) or directly enhance CDD (A), although it supports the overall AML framework including CDD.

This rule is a cornerstone of FATF’s efforts to regulate virtual asset transfers effectively and is adopted by DFSA and other regulators.

Dusting involves sending tiny amounts of crypto to many addresses to later analyze transaction patterns, potentially deanonymizing users — a privacy and AML concern.

Sharing of the same IP address by multiple customers during onboarding can indicate potential fraud, identity manipulation, or collusion, and should be flagged for further investigation. This can be a sign of synthetic identities or multiple accounts controlled by the same person.

Receipt of law enforcement requests (A) usually occurs post-onboarding, while the location (B) or use of foreign IDs (C) is not inherently suspicious.

The Lightning Network is a second-layer payment protocol that enables off-chain transactions, allowing users to conduct fast, low-fee Bitcoin payments without recording every transaction directly on the Bitcoin blockchain. This improves scalability and reduces congestion.

It does not inherently facilitate large payments to decentralized exchanges (A), bridging assets across blockchains (B), or guarantee zero transaction fees (C), though fees are significantly lower than on-chain transactions.

The DFSA and FATF crypto guidance discuss such layer-2 solutions in the context of emerging technological risks and monitoring challenges.

Anonymity-enhanced cryptoassets employ specific technical features to obfuscate the details of transactions and the identities of users to reduce traceability and increase privacy. These include:

Automatic mixing (B):This refers to mechanisms such as coin mixers or tumblers that combine multiple transactions from different users into one batch and redistribute them, breaking the direct transaction link and obscuring the audit trail.

Cryptographic enhancements (D):Techniques such as zero-knowledge proofs, ring signatures, stealth addresses, and confidential transactions are cryptographic protocols that conceal sender, receiver, and transaction amount information, making the blockchain ledger less transparent.

Other options explained:

Proof-of-stake mining (A)is a consensus mechanism and not related to anonymity features.

Secure hashing algorithm 256 (C)is a cryptographic hash function standard but does not directly enhance anonymity.

MetaMask wallet (E)is a non-custodial wallet used mainly for Ethereum and tokens but is not an anonymity tool.

References from official crypto AML guidance and typology papers:

DFSA AML Module and thematic reviews highlight these anonymity techniques as high-risk indicators requiring enhanced due diligence (EDD).

UAE typology papers and FATF virtual asset guidance emphasize the risk posed by anonymity-enhanced cryptoassets using automatic mixing and cryptographic enhancements to circumvent AML controls【AML/VER25/05-24: Sections 6.4, 7.3; 31.92._TFS_Typology_Paper_Eng__4.pdf】.

FATF standards specify that Virtual Asset Service Providers (VASPs) must keep records related to transactions and customer due diligence for at least 5 years after the completion of the transaction or end of the business relationship. This retention period facilitates effective AML investigations and regulatory reviews.

DFSA AML Module aligns with this timeframe, reinforcing that comprehensive record retention supports audit trails and compliance verification.