CCM Regulatory Framework & Requirements 2 — Questions and Answers
Question 1: Under the Bank Secrecy Act (BSA), what is the currency transaction reporting threshold that triggers a mandatory CTR filing?
- $5,000
- $10,000 (Correct answer)
- $25,000
- $50,000
Correct answer: $10,000
The BSA requires financial institutions to file a Currency Transaction Report (CTR) for any cash transaction exceeding $10,000 in a single business day.
Question 2: Which federal agency enforces the Foreign Corrupt Practices Act (FCPA) in relation to securities issuers?
- Department of Justice
- Securities and Exchange Commission (Correct answer)
- Federal Bureau of Investigation
- Office of Foreign Assets Control
Correct answer: Securities and Exchange Commission
The SEC enforces the FCPA's anti-bribery and accounting provisions against companies registered with it, while the DOJ handles criminal enforcement for all entities.
Question 3: A company subject to GDPR receives a data subject access request. What is the standard response deadline?
- 15 calendar days
- 30 calendar days (Correct answer)
- 45 business days
- 60 calendar days
Correct answer: 30 calendar days
GDPR Article 12 requires controllers to respond to data subject access requests within one month (approximately 30 days), extendable by two additional months for complex cases.
Question 4: Which element is NOT a required component of an effective compliance program under the Federal Sentencing Guidelines?
- Written standards and procedures
- Mandatory annual board certification (Correct answer)
- Training and education programs
- A system for reporting compliance concerns
Correct answer: Mandatory annual board certification
The Federal Sentencing Guidelines identify seven hallmarks of an effective program; mandatory annual board certification is not among them, though board oversight is expected.
Question 5: The Dodd-Frank Act's whistleblower program, administered by the SEC, requires a minimum threshold of original information about potential securities violations. What is that threshold?
- The information must relate to insider trading only
- The potential violation must result in a sanction exceeding $1 million (Correct answer)
- The information must be submitted anonymously
- The violation must have occurred within 90 days
Correct answer: The potential violation must result in a sanction exceeding $1 million
Under Dodd-Frank, SEC whistleblower awards are only available when enforcement actions result in sanctions exceeding $1 million, ensuring the program targets significant violations.
Question 6: Which of the following best describes a 'safe harbor' provision in compliance law?
- A penalty waiver granted after a voluntary self-disclosure
- A legal protection shielding compliant entities from certain liabilities (Correct answer)
- A government-approved compliance template for high-risk industries
- An exemption from regulatory reporting available to small businesses
Correct answer: A legal protection shielding compliant entities from certain liabilities
A safe harbor provision provides legal protection to persons or entities that meet specified conditions, shielding them from liability even if their actions would otherwise violate the law.
Question 7: Under HIPAA's Privacy Rule, which category of individuals is authorized to grant a 'personal representative' the right to access a patient's protected health information?
- Only licensed attorneys acting under a notarized power of attorney
- Adults and emancipated minors with capacity to make health care decisions (Correct answer)
- Any immediate family member regardless of patient consent
- State public health officials investigating an outbreak
Correct answer: Adults and emancipated minors with capacity to make health care decisions
HIPAA's personal representative rules allow adults and emancipated minors who have decision-making capacity to designate someone to act on their behalf regarding their PHI.
CCM Regulatory Framework & Requirements 2
Under the Bank Secrecy Act (BSA), what is the currency transaction reporting threshold that triggers a mandatory CTR filing?