ACAMS CCAS - Certified Cryptoasset Anti-Financial Crime Specialist Examination

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.

Indirect exposure refers to a situation where cryptoassets are not directly associated with illicit activity but have transactional links through other addresses that are associated with risky or illicit behavior. Blockchain analytics tools detect these indirect links to flagged addresses, allowing firms to assess risk based on network connections rather than direct ownership or activity.

The DFSA AML guidance and international FATF Virtual Assets guidance explain that indirect exposure is a critical concept for transaction monitoring as it broadens the detection scope beyond direct transactions, flagging assets that might be “tainted” through intermediary addresses.

On-chain forensic analysis uses blockchain data to detect illicit wallet patterns and cluster associations.

Blockchain’s transparent ledger enables investigators to trace transaction histories indefinitely, aiding ML/TF detection.

Consortium blockchains are semi-private networks where governance is shared among authorized participants, offering a balance between decentralization and access control.

FATF defines VASPs as entities that conduct one or more of the following activities:

Exchanging one or more forms of virtual assets (B),

Providing financial services related to initial coin offerings (ICOs) (C),

Exchanging virtual assets for fiat currencies or vice versa (D).

Mining operations (A) and software creation (E) are excluded from the VASP definition as they do not involve financial intermediation. Initial public offerings (IPOs) (F) pertain to traditional securities and are outside the scope of VASP activities.

This definition aligns with FATF Recommendation 15 and DFSA regulatory frameworks.

Mining generates new cryptoassets (A) by rewarding miners for solving complex cryptographic puzzles. It also validates transactions on the blockchain (D) by confirming and recording them in blocks, ensuring the integrity of the ledger.

While mining indirectly contributes to network security, the core security mechanisms involve consensus protocols beyond mining alone (B). Optimizing network functionality (C) is usually a development task rather than a mining function.

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

Integration is the final stage of money laundering, where illicit funds re-enter the economy appearing legitimate — e.g., converting crypto into fiat via exchanges or buying assets.

Ethereum uses an account-based ledger model where balances are maintained per account, similar to bank accounts, and transactions update balances directly. This differs from Bitcoin, Litecoin, and Monero, which use the UTXO (Unspent Transaction Output) model.

Understanding ledger models is important for AML transaction monitoring and blockchain analytics, as account-based systems enable different tracking and risk assessment approaches.