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When all the required information is NOT provided by a person purchasing a cashier's check with $8,000 in currency, what should the bank do?

A.
Refuse the transaction
A.
Refuse the transaction
Answers
B.
Complete the transaction and record available information
B.
Complete the transaction and record available information
Answers
C.
Complete the transaction and file a SAR
C.
Complete the transaction and file a SAR
Answers
D.
Complete the transaction and insist that the customer return with the required information
D.
Complete the transaction and insist that the customer return with the required information
Answers
Suggested answer: A

Which of the following is MOST effective in strengthening an anti-money- laundering program involving cash transactions?

A.
Review all deposits of $25,000 or more
A.
Review all deposits of $25,000 or more
Answers
B.
Complete CTR worksheets on all cash transactions of $5,000 or more
B.
Complete CTR worksheets on all cash transactions of $5,000 or more
Answers
C.
Complete SAR worksheets on all cash transactions of $5,000 or more
C.
Complete SAR worksheets on all cash transactions of $5,000 or more
Answers
D.
Monitor cash transactions of less than $10,000 for suspicious patterns
D.
Monitor cash transactions of less than $10,000 for suspicious patterns
Answers
Suggested answer: D

For which of the following is a bank most likely to be in danger of receiving a cease and desist order?

A.
Repetition in a BSA examination of a noncritical deficiency reported in a previous BSA examination
A.
Repetition in a BSA examination of a noncritical deficiency reported in a previous BSA examination
Answers
B.
Failure to document AML training to its part-time clerical employees
B.
Failure to document AML training to its part-time clerical employees
Answers
C.
A 2 percent error rate on the bank's CTRs
C.
A 2 percent error rate on the bank's CTRs
Answers
D.
Failure to file suspicious activity reports
D.
Failure to file suspicious activity reports
Answers
Suggested answer: D

Which of the following countries are currently subject to the Office of Foreign Assets Control Regulations?

A.
North Korea
A.
North Korea
Answers
B.
Jordan
B.
Jordan
Answers
C.
Bahrain
C.
Bahrain
Answers
D.
Russia
D.
Russia
Answers
Suggested answer: A

What should a bank do when it receives a request from a customer to transfer funds to an individual in Iraq?

A.
Conduct the transfer as requested
A.
Conduct the transfer as requested
Answers
B.
Conduct the transfer if the individual and the financial institution are not on the SDN list
B.
Conduct the transfer if the individual and the financial institution are not on the SDN list
Answers
C.
Block the transfer
C.
Block the transfer
Answers
D.
Conduct the transfer and then notify OFAC immediately
D.
Conduct the transfer and then notify OFAC immediately
Answers
Suggested answer: B

ACME Bank is a $600 million institution with 15 branches within three counties. Because of its proximity to Mexico, the bank has many foreign national customers and makes many foreign wire transfers for its customers. Currently the bank's branch managers print the OFAC list of SDNs and place them in strategic places in each branch. The wire transfer department keeps its own copy of the list. The compliance officer has implemented an annual auditing program to check the bank's compliance with OFAC regulations. The findings of this audit are provided to the bank's board of directors annually. The bank's regulatory agency has indicated to management that the bank has a high risk for BSA/AML/OFAC compliance. Of the following actions, which would be the most effective to strengthen the bank's OFAC compliance?

A.
Conduct compliance audits twice a year
A.
Conduct compliance audits twice a year
Answers
B.
Purchase and implement interdiction software for the wire transfer area
B.
Purchase and implement interdiction software for the wire transfer area
Answers
C.
As an internal control procedure, require the BSA officer to check the OFAC Web site daily for any changes to the SDN list
C.
As an internal control procedure, require the BSA officer to check the OFAC Web site daily for any changes to the SDN list
Answers
D.
Routinely provide account transaction information to federal security agencies so suspicious patterns can be detected
D.
Routinely provide account transaction information to federal security agencies so suspicious patterns can be detected
Answers
Suggested answer: B

State National Bank is a $250 million community bank. It makes a variety of consumer and commercial loans, regularly transmits funds via wire transfers for its customers, and issues commercial and stand-by letters of credit. Which of the following transactions can State National make without checking the OFAC SDN list and without incurring liability?

A.
Send a wire transfer via its correspondent bank in New York for a commercial customer.
A.
Send a wire transfer via its correspondent bank in New York for a commercial customer.
Answers
B.
Sell a cashier's check payable to a third party.
B.
Sell a cashier's check payable to a third party.
Answers
C.
Cash an on-us check over-the-counter for a noncustomer.
C.
Cash an on-us check over-the-counter for a noncustomer.
Answers
D.
None. The bank can be liable for all.
D.
None. The bank can be liable for all.
Answers
Suggested answer: D

FA presents cash to the bank and seeks to wire it to his spouse, RA, in Cub A. The OFAC list identifies RA as a specially designated national. Under OFAC Regulations, what should the bank do?

A.
Block the transfer
A.
Block the transfer
Answers
B.
Conduct the transfer as requested and take no further action
B.
Conduct the transfer as requested and take no further action
Answers
C.
Conduct the transfer as requested and notify OFAC immediately
C.
Conduct the transfer as requested and notify OFAC immediately
Answers
D.
Conduct the transfer only if the bank determines that Cuba is not a blocked country
D.
Conduct the transfer only if the bank determines that Cuba is not a blocked country
Answers
Suggested answer: A

Your institution has identified a transaction by an existing depositor that should be blocked under OFAC requirements. The branch manager contacts you for specific instructions. Before reporting the transaction to OFAC, what should the bank do?

A.
Reject the transaction
A.
Reject the transaction
Answers
B.
Process the transaction
B.
Process the transaction
Answers
C.
Close the customer's account
C.
Close the customer's account
Answers
D.
Place the funds in an interest-bearing account
D.
Place the funds in an interest-bearing account
Answers
Suggested answer: D

Your bank's president comes back from an industry conference and tells the compliance officer that she attended a presentation about OFAC. She heard the bank could be fined for not adhering to OFAC requirements. Thus, she has directed that every bank transaction be reviewed for OFAC compliance. What is the most appropriate statement the compliance officer could make to the bank president?

A.
The bank is already in compliance because OFAC checks are performed on all new depositors
A.
The bank is already in compliance because OFAC checks are performed on all new depositors
Answers
B.
The bank has assessed its OFAC risk and has implemented risk-based OFAC procedures
B.
The bank has assessed its OFAC risk and has implemented risk-based OFAC procedures
Answers
C.
OFAC does not apply because the bank does not conduct business in foreign countries or with foreign nationals
C.
OFAC does not apply because the bank does not conduct business in foreign countries or with foreign nationals
Answers
D.
Banks are usually not fined for OFAC violations unless they conduct transactions with SDNs or blocked countries
D.
Banks are usually not fined for OFAC violations unless they conduct transactions with SDNs or blocked countries
Answers
Suggested answer: B
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