CAPS.Certified Anti-Money Laundering Principal Specialist

1. What you already know, and what this course assumes
2. Predicate offences and the EU criminal-law frame
3. TF, PF and sanctions-evasion as predicate
4. The principal's mandate: ownership, accountability, the Article 11 split

Module assessment, 70% to pass

1. Ledgers, consensus & finality: the audit properties a decision-maker relies on
2. Cryptographic assurance: what hashing and signatures do: and do not: prove
3. Keys, wallets & custody architecture: MPC, multisig, HSM, hot/cold and the controls they imply
4. How transfers actually work: UTXO vs account model, signing, and confirmations
5. Interoperability, bridges & Layer-2: where value leaves your visibility
6. Briefing the board and the supervisor: turning architecture into a control-and-audit position

Module assessment, 70% to pass

1. From economic taxonomy to MiCA legal classes
2. Native assets and the "other crypto-assets" residual
3. Stablecoins: ARTs, EMTs, and the failure cases that built the regime
4. CBDCs and the digital euro: correctly outside the perimeter
5. Classifying the hard cases: tokenisation, NFTs and the DeFi perimeter

Module assessment, 70% to pass

1. Reading the EU rulebook: why "which instrument" is a principal's competence
2. The instrument genealogy, settled once
3. The supervision map: NCA, EBA, ESMA, AMLA, FIU
4. The dated timeline: grandfathering, AMLR, AMLA
5. The EBA soft-law corpus, by name
6. The Travel Rule I: the TFR rulebook
7. The Travel Rule II: operating the rule: reject/return/suspend, counterparty DD, sunrise
8. The transition agenda: building the compliant-by-2027 roadmap

Module assessment, 70% to pass

1. The service perimeter: the ten CASP classes and the calls you sign
2. Getting and holding authorisation: classes, own funds, the dossier, passporting and the grandfathering transition
3. Custody and safekeeping: the conduct obligations you personally own
4. Exchange, brokerage, OTC and sector services: operating conduct and each service's risk shape
5. MiCA Title VI market abuse: the detection-and-report duty you now own
6. The EMT/ART issuer seam: what a CASP owes when it touches a stablecoin
7. Perimeter decisions in practice: making and defending the call

Module assessment, 70% to pass

1. The governance construct: compliance manager, compliance officer, and the board
2. Defending the MLRO: fit-and-proper, independence, and the resourcing case
3. Three lines of defence at a CASP
4. Policy architecture: designing, implementing and improving the suite
5. Control infrastructure: dual controls and sensitive-data access
6. The training & competence programme
7. Quality assurance and management information design
8. Group-wide policies and intragroup outsourcing oversight

Module assessment, 70% to pass

1. The EWRA mandate: what the law requires and what supervisors expect
2. Methodology governance: designing an assessment you can defend
3. Risk identification for CASPs: factors, sources, geography
4. Scoring models: from matrices to multi-dimensional models
5. Predictive analytics and hybrid risk/rule approaches
6. Risk appetite: the board-approved statement that actually binds
7. Residual risk and continuous monitoring of the assessment
8. The worked EWRA: Meridian Digital Markets, end to end
9. Defending the EWRA: the supervisory dialogue

Module assessment, 70% to pass

1. The CDD system: triggers, tiers and calibration to crypto risk
2. Beneficial ownership: the 25%+control methodology, registers and WM & Sovim
3. Remote onboarding at 100% non-face-to-face scale (EBA/GL/2022/15)
4. Enhanced due diligence: PEPs, high-risk third countries and source of wealth
5. Exemptions, limitations and the CDD-failure endgame: decline, exit and the interfaces
6. Blockchain analytics in CDD: attribution confidence and evidential limits

Module assessment, 70% to pass

1. The monitoring mandate and the CASP monitoring architecture
2. Scenario design: from the EWRA to the detection suite
3. Thresholds, tuning and ATL/BTL testing
4. Model validation, documentation and the monitoring-model lifecycle
5. Alert-quality economics and QA sampling
6. Sanctions screening and the travel rule in the monitoring stack
7. Vendor governance for monitoring, analytics and screening

Module assessment, 70% to pass

1. The mechanics of crypto money laundering: placement, layering, integration on-chain
2. Transaction red flags and sender/recipient irregularities: attributed and updated
3. The 2022–26 typology set: chain-hopping, bridges, mixers, AECs and DeFi laundering
4. Tracing methodology and the limits of attribution
5. Case files from the approved library: reading a laundering scheme
6. Investigation supervision: what the MLRO reviews before a file becomes an STR

Module assessment, 70% to pass

1. Forming a defensible suspicion and the internal information flow
2. STR narrative quality and structured crypto evidence
3. Filing: goAML, the reporting duty, and the TFR interface
4. Postponement, freezing, and the FIU feedback loop
5. The tipping-off line: confidentiality after a report exists
6. Reporting to the board: the MI pack (worked example)

Module assessment, 70% to pass

1. The lawful basis: legal obligation, not consent
2. Data-subject rights against AML restrictions
3. DPIAs for transaction monitoring and analytics
4. Breach handling on the dual GDPR/DORA track
5. Retention, minimisation and AMLR data-sharing

Module assessment, 70% to pass

1. DORA and the compliance principal: the ICT-risk framework and the management-body mandate
2. ICT incident classification and the reporting clocks
3. Resilience testing and TLPT: scoping and challenging the programme
4. ICT business continuity, backup and recovery under DORA
5. Encryption, access controls and data security: the DORA ICT-security substance
6. Hot/cold wallet security architecture and third-party ICT & concentration risk

Module assessment, 70% to pass

1. The audit universe and the assurance strategy
2. Internal audit, independent AML audits & skilled-person reviews
3. Auditing blockchain design, consensus & the CASP-specific control stack
4. Evidencing control effectiveness & closing findings

Module assessment, 70% to pass

1. The inspection lifecycle and managing the NCA relationship
2. Enforcement anatomy: the case library, licence revocation and operational restrictions
3. Leading a remediation: findings-letter response, lookbacks, resourcing and board negotiation
4. MLRO/CCO personal liability: administrative, fit-and-proper and criminal exposure
5. Escalation, documenting dissent, and the resignation question

Module assessment, 70% to pass

1. Leading the transition: the AMLR/AMLD6 gap analysis as a project
2. Defending the franchise: bank de-risking, respondent DD and passporting frictions
3. Capstone 1: Defend the EWRA and risk appetite before a mock supervisor
4. Capstone 2: Respond to an NCA findings letter: remediation plan and board paper
5. Capstone 3: The escalation dilemma: the board overrules the MLRO
6. Capstone 4: The sunrise / counterparty-CASP transfer decision

Module assessment, 70% to pass