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NEW QUESTION # 31
If a VASP suspects a transaction involves a sanctioned entity, it must:
Answer: C
Explanation:
Sanctions breaches require immediate reporting to competent authorities and freezing of assets where legally mandated.
NEW QUESTION # 32
A client at a virtual asset service provider (VASP) opened a wallet four weeks earlier with 201,000 USD. The client received a Bitcoin transfer for a total of 565,400 USD. Which is the strongest indication of an illicit source of funds for the client?
Answer: C
Explanation:
Funds moving through multiple intermediary wallets before arriving at the client's wallet indicate layering techniques used to obscure the source of funds, a classic money laundering tactic.
Transferring funds quickly (A) or declaring wealth (B) are less definitive indicators. An untraceable IP (C) raises concerns but is less conclusive than complex transactional layering.
NEW QUESTION # 33
Under DIFC AML rules, which governance body must approve the firm's business-wide risk assessment?
Answer: C
Explanation:
DFSA AML Module requires the Board to approve and oversee the firm's business-wide risk assessment, ensuring accountability at the highest governance level.
NEW QUESTION # 34
Which level of an organization is ultimately responsible for risk oversight?
Answer: B
Explanation:
The ultimate responsibility for risk oversight lies with the Board of Directors. Senior management and the board have the fiduciary and governance duty to ensure that an effective risk management framework, including AML/CFT controls and cryptoasset-specific risks, is in place and functioning properly.
The DFSA GEN Module and AML Module explicitly allocate the highest accountability for compliance and risk oversight to the Board of Directors, while first and second lines support implementation and oversight respectively. The Chief Risk Officer (CRO) supports risk management but the board maintains ultimate accountability.
Key extracts:
GEN Module, Chapter 5: "Responsibility for compliance lies with every member of senior management, with ultimate oversight by the Board." AML Module Section 1.2 & 4.1: "Senior management and Board must ensure appropriate systems and controls for AML/CFT risk management." FATF Recommendation 2 underscores that senior management and boards are accountable for effective AML governance【GEN/VER64/05-24: Chapter 5; AML/VER25/05-24: Sections 1.2, 4.1】.
Thus, D is the correct answer.
NEW QUESTION # 35
Which first step should a VASP take upon detecting repeated transactions to a high-risk wallet?
Answer: D
Explanation:
EDD and internal review determine whether the activity is suspicious before regulatory reporting or freezing actions.
NEW QUESTION # 36
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