Pass the ACAMS AML CCAS Questions and answers with ValidTests

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.

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.

Chain hopping involves moving between blockchains to make tracing harder, often exploiting regulatory gaps.

DAOs are decentralized organizational structures where protocol governance and operational decisions are made collectively by token holders or participants rather than centralized management. This group voting and consensus determine how the protocol functions.

DAOs do not rely on traditional contracts (D) nor necessarily require ongoing human managerial control (A). They are not simply funds with boards voting (C) but represent decentralized governance mechanisms.

FATF Recommendation 13 (Correspondent Banking and Similar Relationships) and its application to VASP–VASP 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 arenotcore 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.

Money laundering risk increases if the business operates in or near high-risk jurisdictions (D) or regions associated with narcotics production (C), as these are common sources of illicit funds.

An increase in volume and users (A) or supporting various cryptoassets (B) alone does not necessarily increase ML risk. Recent licensing (E) may indicate regulatory compliance, potentially lowering risk.

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.

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.

SARs should include detailed transactional information to support investigations, including all types and aggregate amounts of cryptocurrencies purchased, along with fiat currency equivalents. This information provides a clear picture of the subject’s activity and financial scale.

Owner names of destination wallets (B) may not be available; onboarding info (D) is supplementary, and fiat aggregate totals (C) alone are insufficient.

FATF and DFSA guidance recommend comprehensive transactional data inclusion in SARs to facilitate law enforcement.

Art dealers present a high money laundering risk due to the subjective valuation of art, ease of transferring assets, and the potential for using art as a vehicle to conceal illicit funds.

Registered hedge funds (A) and law firms (C) have AML obligations but are generally more regulated. Pharmaceutical companies (B) are less associated with high ML risk.

The DFSA AML and FATF typology papers specifically identify art dealing as a sector with heightened ML risk.