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The BSA officer has just been notified by the chief operations officer that, due to a glitch in the bank's OFAC interdiction software, wires have been regularly transmitted to a bank on the SDN list. Based on the OFAC Enforcement Guidance, what should the BSA Officer do FIRST to attempt to mitigate any penalties?

A.
Review the OFAC wire policies and procedures to determine how the errors occurred
A.
Review the OFAC wire policies and procedures to determine how the errors occurred
Answers
B.
Stop and hold all wires to the bank on the SDN list
B.
Stop and hold all wires to the bank on the SDN list
Answers
C.
Investigate the customer who sends these wires
C.
Investigate the customer who sends these wires
Answers
D.
Self-report the activity to OFAC
D.
Self-report the activity to OFAC
Answers
Suggested answer: B

Bob Jones, president of ACME bank, has had a banking relationship with Linda O'Reilly, a local real estate agent for several years. Ms. O'Reilly keeps most of her deposit accounts with ACME and also has had several personal loans there. Over a three-month time period, Ms. O'Reilly consistently (two or three times a week) brings to the bank a series of money orders in amounts ranging from $7,000 to $15,000, made payable to her in denominations of $1,000, and asks the teller to take them and issue one cashier's check payable to her. After this activity has continued for three months, Mr. Jones notices the frequency of cashier's checks issued to Ms. O'Reilly on a management report. It catches his attention because he does not know why Ms. O'Reilly would need this number of cashier's checks. On inquiry, the head teller explains the weekly transactions. Which of the following statements best describes Mr. Jones's responsibility?

A.
He should immediately file a SAR. There is no logical explanation for this activity.
A.
He should immediately file a SAR. There is no logical explanation for this activity.
Answers
B.
He should immediately file a CTR. Ms. O'Reilly is trying to evade the BSA currency transaction.
B.
He should immediately file a CTR. Ms. O'Reilly is trying to evade the BSA currency transaction.
Answers
C.
He should ask Ms. O'Reilly why she is conducting these transactions and then determine whether to file a SAR.
C.
He should ask Ms. O'Reilly why she is conducting these transactions and then determine whether to file a SAR.
Answers
D.
He is not required to do anything. Mr. Jones is well acquainted with this customer, and it is not illegal to purchase cashier's checks.
D.
He is not required to do anything. Mr. Jones is well acquainted with this customer, and it is not illegal to purchase cashier's checks.
Answers
Suggested answer: C

Which of the following is an accurate statement according to the requirements of the customer identification program regulations?

A.
A bank must always require documentary verification of a customer's identification
A.
A bank must always require documentary verification of a customer's identification
Answers
B.
A bank may waive any part of the CIP requirements if senior management approves the waiver and there is a good cause
B.
A bank may waive any part of the CIP requirements if senior management approves the waiver and there is a good cause
Answers
C.
A physical address or a post office box is acceptable for any new customer
C.
A physical address or a post office box is acceptable for any new customer
Answers
D.
The bank's CIP program must enable it to form a reasonable belief about the identity of the person
D.
The bank's CIP program must enable it to form a reasonable belief about the identity of the person
Answers
Suggested answer: D

When conducting a records search pursuant to a FinCEN request, what must a bank search?

A.
All customer records from the previous five years
A.
All customer records from the previous five years
Answers
B.
All accounts maintained within the previous 12 months and transaction records for 6 months
B.
All accounts maintained within the previous 12 months and transaction records for 6 months
Answers
C.
Only records that can be electronically searched
C.
Only records that can be electronically searched
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D.
Nothing; searches are voluntary
D.
Nothing; searches are voluntary
Answers
Suggested answer: B

A bank is conducting due diligence for a foreign correspondent bank account. Which of the following is NOT required information?

A.
The identities of the correspondent bank's true ownership
A.
The identities of the correspondent bank's true ownership
Answers
B.
Information on the government licenses of the correspondent bank
B.
Information on the government licenses of the correspondent bank
Answers
C.
Copies of the tax return of the correspondent bank
C.
Copies of the tax return of the correspondent bank
Answers
D.
Information on the products and services the correspondent bank offers
D.
Information on the products and services the correspondent bank offers
Answers
Suggested answer: C

Which of the following transactions requires completion of FinCEN Form 104, a CTR?

A.
Deposit of checks totaling $12,000 to a checking account
A.
Deposit of checks totaling $12,000 to a checking account
Answers
B.
Cash purchase of a cashier's check for $7,800
B.
Cash purchase of a cashier's check for $7,800
Answers
C.
Cash withdrawal of $3,000 from a checking account
C.
Cash withdrawal of $3,000 from a checking account
Answers
D.
Cashing of a $14,000 check for a customer
D.
Cashing of a $14,000 check for a customer
Answers
Suggested answer: D

When is it permissible for a bank that is a government securities broker or dealer to refrain from filing a Form G-FIN-5 or a Form MSD-5 when an employee terminates the associated person status?

A.
When the employee files the form
A.
When the employee files the form
Answers
B.
When the bank does not have all the necessary information and notifies its regulatory agency
B.
When the bank does not have all the necessary information and notifies its regulatory agency
Answers
C.
When the employee's status is reinstated within six months
C.
When the employee's status is reinstated within six months
Answers
D.
When the employee remains employed by the bank and the bank notifies its regulatory agency
D.
When the employee remains employed by the bank and the bank notifies its regulatory agency
Answers
Suggested answer: D

When is it possible for a bank to be exempted from compliance with some of the Government Securities Act custodial regulations?

A.
When the bank maintains its securities in the ordinary course of business
A.
When the bank maintains its securities in the ordinary course of business
Answers
B.
When the bank has procedures in place to make sure it complies with the custodial regulations of its federal regulatory agency
B.
When the bank has procedures in place to make sure it complies with the custodial regulations of its federal regulatory agency
Answers
C.
When the bank does not hold itself out as a government securities broker or dealer
C.
When the bank does not hold itself out as a government securities broker or dealer
Answers
D.
When the bank uses more than the normal standard of care when maintaining possession and control of securities
D.
When the bank uses more than the normal standard of care when maintaining possession and control of securities
Answers
Suggested answer: B

Under what circumstances will a G-FINW (a withdrawal as a government securities dealer) become effective in less than 60 days?

A.
If the bank requests a shorter time period
A.
If the bank requests a shorter time period
Answers
B.
If the regulatory agency determines that a shorter time period would be appropriate
B.
If the regulatory agency determines that a shorter time period would be appropriate
Answers
C.
If the bank ceases doing business as a securities dealer
C.
If the bank ceases doing business as a securities dealer
Answers
D.
If the bank has no employees that qualify as associated persons
D.
If the bank has no employees that qualify as associated persons
Answers
Suggested answer: B

Which of the following actions is NOT a custodial requirement of the Government Securities Act?

A.
Keeping possessory government securities in a vault with dual control access
A.
Keeping possessory government securities in a vault with dual control access
Answers
B.
Segregating government securities from bank assets
B.
Segregating government securities from bank assets
Answers
C.
Keeping government securities free of liens, claims, and charges.
C.
Keeping government securities free of liens, claims, and charges.
Answers
D.
Issuing safekeeping receipts for securities
D.
Issuing safekeeping receipts for securities
Answers
Suggested answer: A
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