CVCLD study plan
CVCLD · Give each week a clear focus.
8 weeks · About 7 hours per week
Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF)
Build a one-page map of the AML/CTF obligations that apply to virtual asset service providers, covering customer due diligence, ongoing monitoring, suspicious activity reporting, and recordkeeping.
Explain in writing how the risk-based approach changes CDD depth for low-risk versus high-risk virtual currency customers, citing at least three risk factors specific to crypto (mixers, anonymity-enhanced coins, unhosted wallets).
Draft a suspicious activity narrative for a hypothetical peer-to-peer exchange scenario, including the facts, the red flags, and the recommended escalation path.
Define the four pillars of an AML program and match each to a concrete control a crypto business would implement.
Your checkpoint
A 600-word AML/CTF control matrix mapping each obligation to a specific virtual currency control, plus one complete suspicious activity narrative.
Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) & Virtual Currency Fundamentals and Blockchain Technology
Trace how blockchain transparency supports and complicates transaction monitoring, distinguishing public-ledger analysis from off-chain data sources.
Distinguish consensus mechanisms (proof of work, proof of stake) and explain why the distinction matters for settlement finality and for AML risk assessment.
Classify the main wallet types (custodial, unhosted, hardware, hot, cold) and state the CDD and travel-rule implications of each.
Write a short analysis of how chain-hopping, cross-chain bridges, and decentralized exchanges create layering opportunities for illicit funds.
Your checkpoint
A 500-word transaction monitoring playbook section describing at least five blockchain-derived red flags and the follow-up action for each.
Securities and Commodities Regulation of Digital Assets
Determine whether a given digital asset is a security using the investment-contract analysis, and apply the reasoning to three different token fact patterns.
Explain how commodity regulation applies to virtual currencies and where the boundary between securities and commodities regulation falls for a given token.
Summarize the registration, disclosure, and licensing consequences that follow from a token being classified as a security.
Identify the market-conduct rules (manipulation, insider trading, custody) that apply to digital asset trading venues.
Your checkpoint
A three-token classification memo (one security, one commodity, one contested) with reasoning and the regulatory consequences of each conclusion.
Money Transmission and Payment Systems Licensing
Determine when a virtual currency business is engaged in money transmission versus acting as a mere software provider or payment processor.
Outline the state licensing process end to end, including application components, surety bond requirements, permissible investments, and net-worth thresholds.
Compare money transmission licensing with the federal registration regime for money services businesses and explain how the two interact.
Explain how the travel rule applies to transmittals involving unhosted wallets and what information collection is triggered.
Your checkpoint
A licensing readiness checklist covering at least 15 items a crypto money transmitter must satisfy before accepting its first customer.
Taxation of Virtual Currency Transactions & Securities and Commodities Regulation of Digital Assets
Classify common virtual currency events (mining, staking, airdrops, forks, sales, payments for goods) as ordinary income, capital gain, or non-taxable, and justify each classification.
Compute cost basis and gain or loss for a hypothetical series of trades using the appropriate basis and identification methods.
Explain the reporting obligations that fall on exchanges and on individual taxpayers, including information returns and the treatment of payments made in virtual currency.
Revisit the securities and commodities classification from week 3 and state how each classification changes the tax and reporting analysis.
Your checkpoint
A worked tax scenario with at least eight transactions, showing basis, gain or loss per transaction, and total taxable income.
Consumer Protection, Fraud, and Market Conduct
Identify the deceptive practices most common in virtual currency markets (fake endorsements, pump-and-dump schemes, romance and investment fraud, rug pulls) and the conduct rules each violates.
Draft customer-facing disclosure language that clearly explains volatility, custody risk, and irreversibility of transactions.
Design a complaint-handling and advertising-review workflow that would catch misleading promotional claims before publication.
Explain how market-conduct expectations apply to employees trading their own accounts and how to control that conflict.
Your checkpoint
An advertising review checklist with at least 12 pass/fail criteria plus a one-page customer disclosure draft.
Sanctions, Export Controls, and Cross-Border Compliance
Screen a set of hypothetical counterparties and wallet addresses against sanctions lists and document the escalation decision for each hit or near-hit.
Explain how sanctions exposure arises through wallet addresses, mixers, and indirect ownership, and how to handle a blocked or rejected transaction.
Summarize export-control and cross-border data considerations that arise when a crypto business serves customers in multiple jurisdictions.
Describe how to conduct enhanced due diligence on a counterparty in a higher-risk jurisdiction without breaching data protection limits.
Your checkpoint
A sanctions screening decision log for ten hypothetical alerts, each with a documented disposition and rationale.
Compliance Program Governance, Risk Management, and Ethics & Virtual Currency Fundamentals and Blockchain Technology & Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF)
Build a compliance risk assessment that scores inherent risk and control effectiveness across all eight exam domains.
Design a three-lines-of-defense structure for a virtual currency firm and assign each domain's controls to the appropriate line.
Write an ethics scenario response addressing a conflict between commercial pressure and a compliance obligation, and state the escalation path.
Complete a timed 60-question mixed practice set and analyze every missed item by domain to identify remaining gaps.
Your checkpoint
A full compliance risk assessment with a domain-by-domain heat map, plus a written gap-remediation plan for the three weakest domains.
Milestones
Week 2: You can explain, without notes, how blockchain transparency both helps and hinders AML monitoring, and you have completed the AML control matrix and monitoring playbook.
Week 4: You can classify a new token as security or commodity and state the licensing consequences, and your licensing readiness checklist is complete with no unresolved items.
Week 6: You have scored at least 70% on a self-made 40-question set covering domains 1 through 6, and your tax scenario and advertising checklist are finished.
Week 8: You have scored at least 80% on the timed 60-question mixed practice set and have a written remediation plan for every domain scoring below 75%.