Free ACAMS CCAS Practice Exam with Questions & Answers

Suspicious Activity Reports (SARs) are a critical tool for law enforcement agencies. They are primarily used to develop intelligence on potential new criminal targets and to confirm or expand information about existing investigations. SARs do not serve as direct evidence of money laundering in court but provide leads and context that enable law enforcement to build cases.

The DFSA’s thematic reviews and AML guidance clarify that SARs assist in identifying emerging crime patterns and help intelligence units track suspicious transactions over time. They also allow law enforcement to corroborate data from other sources.

SARs help:

Develop intelligence on new targets (C) by revealing previously unknown suspicious behavior.

Confirm or develop information on existing targets (D) by adding transactional data and context.

Identifying regulatory failings (A) is primarily a supervisory function, and SARs themselves are not evidence for prosecution (B) but intelligence inputs.

Therefore, optionsCandDare correct.

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

Privacy coins like Monero use cryptographic features to obscure transaction details, increasing AML risk and regulatory scrutiny.

The risk-based approach requires tailoring AML/CFT controls to the level of assessed risk, enhancing due diligence for higher-risk customers.

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 Recommendation 20 mandates that STRs be filed whenever there is suspicion or reasonable grounds to suspect criminal proceeds, regardless of the transaction value. This is mirrored in DFSA and FSRA AML regulations, ensuring that the reporting obligation is triggered by suspicion, not just thresholds.

Staff must report any suspicious activity immediately to the designated Money Laundering Reporting Officer (MLRO) or equivalent within their organization. The MLRO is responsible for assessing the suspicion and deciding on escalation to the relevant authorities.

Informing customers (A) could compromise investigations. Reporting directly to financial investigation units (B) is not the staff member’s role. Monitoring transactions without reporting (D) delays required action and risks regulatory non-compliance.

DFSA AML Module and FATF Recommendations emphasize timely internal reporting to designated officers as the first step in managing suspicious activity.

In the context of AML/CFT frameworks for cryptoassets, the investigation of transaction histories involves blockchain analysis tools to trace the flow of funds to and from crypto addresses. Specifically, it is essential to assess whether the addresses involved have had prior exposure to illicit activities such as known darknet marketplaces, ransomware payments, or sanctioned entities. This form of "address screening" helps identify potentially tainted cryptoassets.

The DFSA AML Module and associated guidance emphasize that transaction monitoring for cryptoassets requires analyzing the provenance of funds, not just ownership. While identifying the owner is part of customer due diligence (CDD), the transactional exposure itself reveals laundering risks embedded in the chain of transfers.

Extract from DFSA AML Module and COB Module on Crypto Business Rules:

"Transaction monitoring systems must include blockchain analysis to detect suspicious activity related to crypto tokens, including tracing transactions against known illicit sources."

"Enhanced due diligence (EDD) is required when a cryptoasset transaction involves addresses or wallets with a history of illicit activity."

"Risk-based approaches must integrate forensic review of transaction histories to assess financial crime risks in crypto asset transfers"【AML/VER25/05-24: Sections 6.3, 7.3, 13.3; COB/VER45/05-24: Sections 6.13, 15】.

Therefore, assessing the receiving exposure of cryptoasset addresses to illicit activity (Option C) is the most direct and effective method to detect laundering.

Standard due diligence typically involves reviewing negative news and verifying beneficial ownership to understand the customer’s background and potential risk factors.

Dark web forums (B) and blockchain exposure (D) are more advanced or enhanced due diligence techniques, used when higher risk is identified.

Smart contracts execute predetermined conditions automatically on blockchain, enabling decentralized applications and services.