To identify and assess the money laundering risks emerging from virtual assets, countries should ensure that virtual asset service providers are: (Select Two.)
Correct Answer: B, C
To effectively mitigate money laundering risks in the virtual asset sector, countries must ensure that Virtual Asset Service Providers (VASPs) are subject to AML regulations (B), which provide the legal framework for risk-based customer due diligence and reporting suspicious activities. Additionally, VASPs must maintain effective monitoring systems (C) that enable the detection and reporting of suspicious transactions.
While connection to regulated financial institutions (A) and beneficial ownership evaluation (E) are important components of AML frameworks, the foundational requirements per FATF and DFSA guidance focus on regulatory oversight and operational controls.
Jurisdictional regulatory expectations (D) influence enforcement but do not replace the need for direct AML regulatory application on VASPs.
Which operational risk mitigation practice by virtual asset service providers (VASPs) is most effective when considering their relationships with other VASPs?
Correct Answer: D
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.
What is indirect exposure in regards to blockchain analytics transaction monitoring?
Correct Answer: B
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.
FATF Guidance on Virtual Assets and VASPs emphasizes monitoring both direct and indirect exposure of wallets to illicit activity.
DFSA AML Module Section 13 on Suspicious Activity Reports requires firms to incorporate indirect exposure assessments in their monitoring systemsAML/VER25/05-24: Sections 4.1, 6.3, 13.3; FATF VA Guidance 2021.
Therefore, B is the correct definition.
What is the most pertinent item for a cryptoasset money services business to include in a suspicious activity report?
Correct Answer: A
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.
An analyst at a virtual asset service provider (VASP) that white-labels its exchange solution to other cross-border VASPs is developing a VASP onboarding procedure. Under Financial Action Task Force Recommendation 13, which CDD practices should be applied to such relationships? (Select Three.)
Correct Answer: C, D, E
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 are not core 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.
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