CPB Regulatory Compliance & Ethical Standards 2

Question 1

Under USA PATRIOT Act Section 312, a 'private banking account' for a non-U.S. person that triggers enhanced due diligence requires a minimum aggregate deposit of:

Accepted Answer

$1,000,000

Answer

Section 312 defines a private banking account as one requiring at least $1,000,000 in aggregate deposits for a non-U.S. person, assigned to a bank liaison.

Question 2

Under the Section 312 enhanced due diligence program for private banking, a bank must take reasonable steps to determine which of the following about the account?

Accepted Answer

The source of funds deposited

Answer

Section 312 requires steps to find the identity of nominal and beneficial owners, the source of funds, and whether the client is a senior foreign political figure.

Question 3

A private banker learns that a long-time client has become the subject of a SAR filed by the bank. The client asks whether the bank has reported him. What should the banker do?

Accepted Answer

Not disclose the SAR or any information that would reveal its existence

Answer

Federal law prohibits disclosing a SAR or any information that would reveal its existence (no tipping off).

Question 4

When no suspect has been identified, a bank may delay filing a SAR to find a suspect, but filing may not exceed how many calendar days after initial detection?

Accepted Answer

60 days

Answer

The normal 30-day deadline can be extended by 30 days to find a suspect, with a 60-day maximum.

Question 5

Under the FinCEN CDD Rule, the ownership prong requires identifying each individual who owns, directly or indirectly, what share of a legal entity customer's equity interests?

Accepted Answer

25% or more

Answer

The ownership prong covers each individual holding 25% or more, plus one individual with significant control.

CPB - Certified Private Banker Practice Test

CPB - Certified Private Banker Practice Test

CPB Regulatory Compliance & Ethical Standards 2