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CAMS · Question #918

CAMS Question #918: Real Exam Question with Answer & Explanation

The correct answer is A. Allowing clients lo transact anonymity-enhanced tokens B. Onboardlng of clients who are residents abroad. Including those with politically exposed person D. Offering services to VASPs established in jurisdictions that are not FATF compliant F. Lack of adequate IP address tracking capabilities. VASPs face heightened AML risk from privacy-enhancing tokens, PEP clients, non-FATF-compliant counterparty jurisdictions, and gaps in transaction monitoring capabilities.

Question

A compliance manager at a virtual asset service provider (VASP) is evaluating its business and its impact on AML policies. Which of the following features of the VASP's business would be of greatest concern? (Select Four.)

Options

  • AAllowing clients lo transact anonymity-enhanced tokens
  • BOnboardlng of clients who are residents abroad. Including those with politically exposed person
  • CEnabling transfer of tokens from one blockchain to another
  • DOffering services to VASPs established in jurisdictions that are not FATF compliant
  • EOperating a network of crypto ATMs charging high fees
  • FLack of adequate IP address tracking capabilities

Explanation

VASPs face heightened AML risk from privacy-enhancing tokens, PEP clients, non-FATF-compliant counterparty jurisdictions, and gaps in transaction monitoring capabilities.

Common mistakes.

  • C. Cross-chain token transfers carry some obfuscation risk but are a standard interoperability function and are not among the highest-concern features compared to privacy coins, PEP exposure, non-compliant jurisdictions, or monitoring capability gaps.
  • E. High fees at crypto ATMs are primarily a consumer protection concern and do not represent a primary AML red flag in the way anonymity features or jurisdictional deficiencies do.

Concept tested. VASP AML risk factors under FATF guidance

Reference. https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-rba-virtual-assets-2021.html

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