BSA/AML Flashcards

1
Q

Which of the following businesses would be eligible to be an exempt person
under the requirements of the Bank Secrecy Act?
a. Jackson’s Used Cars
b. Evanston Recreational Boats
c. Al Williams Seafood Restaurant
d. Goldsmith Aircraft Distributors

A

c. Al Williams Seafood Restaurant

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2
Q

Fastfood, Inc., a nationwide restaurant chain, opened an account at First National Bank last year. Fastfood is making daily cash deposits in amounts of $15,000 to $20,000. First National needs to determine if this company is an exempt person. What should the bank do first?

a. Because the restaurant is an established depositor, the bank should provide an unlimited exemption for cash deposits and withdrawals.
b. The bank should look in the newspaper or on the Internet to determine if Fastfood, Inc.’s, stock appears on one of the listed exchanges.
c. The bank should ask the company if it qualifies as a listed business.
d. The bank should perform a corporate records check to determine if the company is chartered in the United States.

A

b. The bank should look in the newspaper or on the Internet to determine if Fastfood, Inc.’s, stock appears on one of the listed exchanges.

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3
Q

First National Bank is attempting to determine which of the following customers would qualify as exempt persons:
Nationwide Foods, Inc., is a national company with stock listed on the New York Stock Exchange
National Paper Products, is a wholly owned subsidiary of Nationwide Foods, Inc.
Products Incorporated, a depositor for three months, is a regional company whose stock is designated a NASDAQ Capital Markets Company and that sells and leases large boats
Century Enterprises, a local company owning several local restaurants, is a long-time bank customer and frequently makes cash deposits in excess of $10,000. All of Century’s stock is owned by a local family.
Which of these customers would qualify as an exempt person?

a. All except for Nationwide Foods, Inc.
b. All except for National Paper Products
c. All except for Century Enterprises
d. All except for Products Incorporated

A

d. All except for Products Incorporated

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4
Q

James Walker DBA Walker Enterprises has been a customer of the bank for one month. The company told the bank that it would regularly make deposits in excess of $10,000 because it operates several laundromats in the city. The bank performed a background check on the company before opening the account. For its first 30 days, the company made 12 large cash deposits. Can the bank exempt this company now? Why or why not?

a. No. It is a not a corporation, but a sole proprietorship.
b. No. It has not maintained an account at the bank for 12 months.
c. No. It operates an ineligible business.
d. Yes. The bank conducted due diligence on the customer to determine that it had legitimate large cash transactions.

A

d. Yes. The bank conducted due diligence on the customer to determine that it had legitimate large cash transactions.

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5
Q

First National Bank has several exempt customers.
Alpha is an exempt person because its stock is listed on a major stock exchange.
Beta is an exempt person because it meets the non-listed customer requirements.
Zeta is exempt because it is a payroll customer.
For which customer(s) must the bank conduct an annual review to determine its continuing eligibility to be exempt from CTR filings?
a. Alpha
b. Beta
c. Zeta
d. Alpha, Beta, and Zeta

A

d. Alpha, Beta, and Zeta

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6
Q

Mrs. Evans, a customer of First National Bank, deposits $15,000 in cash to her account. During the transaction, Mrs. Evans explains that she received the money in the mail from her sister in Europe. What responsibility does the bank have?
a. Complete a Currency Transaction Report (CTR)
b. Complete a United States Customs form 4790 (CMIR
c. Complete both a currency transaction report and a CMIR
d. Complete a CTR and encourage Mrs. Evans to file a CMIR

A

d. Complete a CTR and encourage Mrs. Evans to file a CMIR

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7
Q

For how long must a bank keep records of transactions involving currency in amounts greater than $10,000?
a. 2 years
b. 3 years
C. 5 years
d. 7 years

A

C. 5 years

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8
Q

The manager of Main Street branch calls and relates the following information: John Smith purchased a cashier’s check for $1,000 cash at 10:00 A.M. on Tuesday. At 11:30 A.M. Mr. Smith returned and purchased a cashier’s check for $2,500 cash and deposited traveler’s checks totaling $9,000 into his checking account. At 4:00 P.M. Mr. Smith returned and deposited $8,000 cash into his checking account. This deposit was after normal banking hours, so it was recorded as of Wednesday’s business date. What action should the bank take?
a. None, because no single cash transaction exceeded $10,000
b. File a Currency Transaction Report (CTR) for $11,500
c. Record the $1,000, $2,500, and $9,000 transactions on the bank’s monetary instrument sales log because the total exceeds the $3,000 threshold
d. Record the $1,000 and $2,500 transactions on the bank’s monetary instrument sales log because the total exceeds the $3,000 threshold

A

d. Record the $1,000 and $2,500 transactions on the bank’s monetary instrument sales log because the total exceeds the $3,000 threshold

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9
Q

Records that must be retained for deposit accounts include which of the following?
a. Average daily balance
b. Overdraft history
c. All amounts of currency deposited or withdrawn
d. Customer’s identity

A

d. Customer’s identity

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10
Q

Mammoth Enterprises is a new customer to the bank. It is a wholly owned subsidiary of Mammoth Corporation. Which of the following statements, if true, would make Mammoth Enterprises an exempt customer at the bank?

a. ‘ Mammoth Corporation is a London corporation, trading on the London Stock Exchange
b. Mammoth Corporation is a U.S. corporation with unlisted stock.
c. Mammoth Corporation is a U.S. corporation trading on the American Stock Exchange.
d. Mammoth Enterprises is a U.S. corporation primarily in the investment banking business.

A

c. Mammoth Corporation is a U.S. corporation trading on the American Stock Exchange.

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11
Q

In April Lillian Redmond, the teller supervisor for First National Bank,
discovers five counterfeit $20 bills in several teller drawers. In May and in June she discovers two additional counterfeit $20 bills. She has no knowledge of criminal activity on the part of any of the bank’s employees or customers. She does not suspect any particular person in this transaction. Which of the following statements is true?

a. Ms. Redmond must report the counterfeit funds on a SAR and must name the most likely individual(s) on the report.
b. Ms. Redmond must report the counterfeit funds on a SAR but is not required to name any individual(s) on the report.
c. Ms. Redmond need not file a SAR on this incident because the total amount is less than $25,000.
d. Ms. Redmond need not report this incident on a SAR because each incident is less than $5,000.

A

c. Ms. Redmond need not file a SAR on this incident because the total amount is less than $25,000.

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12
Q

Martha Whitmire, the BSA Compliance Officer for First National Bank, is Regulatory responsible for monitoring the bank’s daily currency activity and wire transfers, Compliance for compliance with information retention and reporting requirements.
Ms. Whitmire notices during her review on March 10 that, during the previous two weeks, a transaction occurred on the same account several times during the week. The activity appeared at one branch office as cash deposits in dollar
amounts under the reporting thresholds. Ms. Whitmire discusses this activity with the branch manager and determines that this same deposit activity occurred several times during the previous six weeks. She then conducts a more extensive
examination of the account’s activity for several months and discovers that deposits were made at one branch office and purchases of bank cashier’s checks requirements were made by withdrawals from the same account at a different branch office. All withdrawals and purchases of cashier’s checks were for the identical amount requirements
as the cash deposits. Which statement best describes Ms. Whitmire’s responsibility?

a. Complete a CTR for each of the cash activities at the branch office financial accounts
b. Make no report of the activities because the transactions were not Purchases of monetary discovered until after the 15-day reporting deadline instruments Funds transfers
c. Report the account activity to senior management for further review Due diligence for foreign
d. Report the account activity as suspicious account activity and recommend correspondent banks that a SAR be filed and private banking accounts and prohibitions on accounts

A

d. Report the account activity as suspicious account activity and recommend correspondent banks that a SAR be filed and private banking accounts and prohibitions on accounts

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13
Q

Bob Jones, president of ACME bank, has had a banking relationship with Linda for foreign shell banks
O’Reilly, a local real estate agent for several years. Ms. O’Reilly keeps most of Information-sharing procedures to deter
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
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.
b. He should immediately file a CTR. Ms. O’Reilly is trying to evade the BSA currency transaction.
c. He should ask Ms. O’Reilly why she is conducting these transactions and then determine whether to file a SAR.
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.

A

c. He should ask Ms. O’Reilly why she is conducting these transactions and then determine whether to file a SAR.

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14
Q

Which of the following is an accurate statement according to he requirements of the customer identification program regulations?
a. A bank must always require documentary verification of a customer’s identification
b. A bank may waive any part of the CIP requirements if senior management approves the waiver and there is a good cause
c. A physical address or a post office box is acceptable for any new customer
d. The bank’s CIP program must enable it to form a reasonable belief about the identity of the person

A

d. The bank’s CIP program must enable it to form a reasonable belief about the identity of the person

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15
Q

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

a. All customer records from the previous five years
b. All accounts maintained within the previous 12 months and transaction records for 6 months
c. Only records that can be electronically searched
d. Nothing; searches are voluntary

A

b. All accounts maintained within the previous 12 months and transaction records for 6 months

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16
Q

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
b. Information on the government licenses of the correspondent bank
C. Copies of the tax return of the correspondent bank
d. Information on the products and services the correspondent bank offers

A

C. Copies of the tax return of the correspondent bank

17
Q

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

a. Deposit of checks totaling $12,000 to a checking account
b. Cash purchase of a cashier’s check for $7,800
c. Cash withdrawal of $3,000 from a checking account
d. Cashing of a $14,000 check for a customer

A

d. Cashing of a $14,000 check for a customer

18
Q

On which of the following loans must a bank maintain records under the Bank Secrecy Act?
a. All loans exceeding $5,000 and secured by real property
b. All loans exceeding $5,000, but not secured by real property
C. All loans exceeding $10,000 and secured by real property
d. All loans exceeding $10,000, but not secured by real property

A

d. All loans exceeding $10,000, but not secured by real property

19
Q

An individual comes into the bank and makes a $6,000 cash deposit into a checking account. At the same time, the individual buys a $7,000 cashier’s check with cash. According to the Bank Secrecy Act, what is the bank is required to do?
a. File a SAR for $13,000
b. File a CTR for the $6,000 cash deposit
C. Aggregate the transactions and retain information about the purchase of the cashier’s check
d. Obtain the recordkeeping information for the purchase of the cashier’s check and complete a CTR for the total cash-in transaction of $13,000

A

d. Obtain the recordkeeping information for the purchase of the cashier’s check and complete a CTR for the total cash-in transaction of $13,000

20
Q

Which of the following is NOT considered an acceptable form of identification for an individual when completing a CTR?
a. U.S. passport
b. Long-term deposit account relationship
c. State-issued photo identification (e.g., driver’s license)
d. Photo identification card issued by a local government agency

A

b. Long-term deposit account relationship

21
Q

Which of the following customers may be exempted from CTR requirements under Phase II of the Bank Secrecy Act?
a. Government agencies
b. Correspondent banks
c. Payroll customers
d. Businesses whose stocks are traded on a national stock exchange

A

c. Payroll customers

22
Q

In which of the following circumstances is it LEAST appropriate for a bank to file a SAR regarding Internet activity?

a. Bank determines that one of its customers is the victim of identity theft
b. Bank becomes aware of identity theft of its domain name (i.e., another entity selects a name similar to the bank’s in order to confuse customers and obtain confidential financial information)
c. Bank discovers that someone has hacked into its data system in order to obtain confidential customer data
d. Bank determines through its transaction-monitoring program that a customer is making electronic transfers between his own checking and savings accounts that are just below the $10,000 reporting level

A

d. Bank determines through its transaction-monitoring program that a customer is making electronic transfers between his own checking and savings accounts that are just below the $10,000 reporting level

23
Q

When completing and filing a SAR, what is the bank NOT required to do?

a. Submit a copy of the supporting documentation with the SAR
b. Submit the SAR within 30 days of the initial detection of facts
c. Report the SAR information to the bank’s board of directors
d. Maintain a copy of the SAR and supporting documentation for 5 years

A

a. Submit a copy of the supporting documentation with the SAR

24
Q

What should a bank’s Bank Secrecy Act compliance program include?
a. All lobby notice requirements
b. The one-year record retention requirements
c. Designation of individual(s) responsible for day-to-day compliance
d. A list of types of loans covered by the Act

A

c. Designation of individual(s) responsible for day-to-day compliance

25
Q

A routine review of account records reveals that suspicious activity involving foreign currency has occurred in the account of one of the bank’s directors. Which of the following actions should be taken FIRST?

a. A SAR should be filed.
b. The bank’s board of directors should discuss the account activity without the affected director being present.
c. The bank’s president should meet with the affected director to discuss the account activity.
d. The bank should file a CTR, checking the box that indicates the report is for suspicious activity.

A

a. A SAR should be filed.

26
Q

A compliance officer is constructing a review of a transaction in which M, a deposit account customer, used cash to purchase travelers’ checks in an amount of $4,000. The compliance officer must determine compliance with financial recordkeeping and currency reporting regulations. Which of the following pieces of information must be part of the bank’s records for this transaction?

a. M’s date of birth
b. M’s deposit account number
c. The serial numbers of the travelers’ checks purchased
d. The name of the branch where the transaction occurred

A

c. The serial numbers of the travelers’ checks purchased

27
Q

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
b. Complete the transaction and record available information
C. Complete the transaction and file a SAR
d. Complete the transaction and insist that the customer return with the required information

A

a. Refuse the transaction

28
Q

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
b. Complete CTR worksheets on all cash transactions of $5,000 or more
c. Complete SAR worksheets on all cash transactions of $5,000 or more
d. Monitor cash transactions of less than $10,000 for suspicious patterns

A

d. Monitor cash transactions of less than $10,000 for suspicious patterns

29
Q

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
b. Failure to document AML training to its part-time clerical employees
c. A 2 percent error rate on the bank’s CTRS
d. Failure to file suspicious activity reports

A

d. Failure to file suspicious activity reports