APRP BSA/AML/OFAC Compliance

Question 1

Under the Bank Secrecy Act (BSA), a financial institution must file a Suspicious Activity Report (SAR) when a transaction involves at least what dollar threshold AND the institution suspects illegal activity?

Accepted Answer

$5,000

Answer

For most transaction types, the BSA SAR filing threshold is $5,000 (or $2,000 for money services businesses in certain situations). The $10,000 threshold applies to Currency Transaction Reports (CTRs) for cash transactions, not SARs. A SAR must be filed within 30 days of detection.

Question 2

OFAC (Office of Foreign Assets Control) sanctions compliance in payment processing PRIMARILY requires institutions to:

Accepted Answer

Screen transactions against lists of Specially Designated Nationals (SDNs) and blocked persons or entities

Answer

OFAC administers U.S. economic sanctions. Payment processors must screen senders, receivers, and related parties against OFAC's SDN List and other sanctions lists, blocking or rejecting prohibited transactions. W-9s relate to tax compliance; CTRs relate to BSA cash reporting; the Fed does not pre-approve international ACH.

Question 3

What is the PRIMARY objective of a Know Your Customer (KYC) program in the context of payments risk?

Accepted Answer

To verify customer identity and assess money laundering risk before and throughout the customer relationship

Answer

KYC programs are AML tools designed to verify who customers are and assess the risk they pose for financial crimes such as money laundering or terrorist financing. This is an ongoing obligation — not a one-time marketing or consent activity.

Question 4

A Currency Transaction Report (CTR) must be filed with FinCEN for cash transactions that exceed which threshold in a single business day?

Accepted Answer

$10,000

Answer

BSA regulations require financial institutions to file a CTR for any cash transaction (or multiple related cash transactions) exceeding $10,000 in a single business day. This is distinct from the SAR threshold of $5,000. CTRs are mandatory regardless of whether illegal activity is suspected.

Question 5

'Structuring,' also known as 'smurfing,' is a BSA violation that involves which of the following?

Accepted Answer

Breaking large cash transactions into smaller amounts specifically to avoid triggering Currency Transaction Report filing requirements

Answer

Structuring is the illegal practice of deliberately breaking up large cash transactions into amounts below the $10,000 CTR reporting threshold to evade detection. It is a federal crime under 31 U.S.C. § 5324 regardless of whether the underlying funds are from illegal activity.

APRP - Accredited Payments Risk Professional Practice Test

APRP - Accredited Payments Risk Professional Practice Test

APRP BSA/AML/OFAC Compliance