CRCM Bank Secrecy Act and Anti-Money Laundering 1 — Questions and Answers
Question 1: Under the Bank Secrecy Act, financial institutions must file a Currency Transaction Report (CTR) for cash transactions exceeding what threshold?
- $5,000
- $10,000 (Correct answer)
- $25,000
- $50,000
Correct answer: $10,000
The BSA requires CTR filing for cash transactions exceeding $10,000 in a single business day.
Question 2: Which federal agency has primary responsibility for administering the Bank Secrecy Act for depository institutions?
- SEC
- FDIC
- FinCEN (Correct answer)
- OCC
Correct answer: FinCEN
The Financial Crimes Enforcement Network (FinCEN), a bureau of the Treasury Department, administers the BSA.
Question 3: A Suspicious Activity Report (SAR) must generally be filed within how many days of detecting a suspicious transaction?
- 15 days
- 30 days (Correct answer)
- 45 days
- 60 days
Correct answer: 30 days
SARs must be filed within 30 calendar days of the date of initial detection of suspicious activity.
Question 4: What is 'structuring' in the context of BSA compliance?
- Breaking up transactions to avoid CTR filing requirements (Correct answer)
- Organizing a bank's internal compliance team
- Setting up a tiered customer risk rating system
- Bundling multiple accounts under one customer profile
Correct answer: Breaking up transactions to avoid CTR filing requirements
Structuring (also called 'smurfing') is illegally breaking transactions into smaller amounts to avoid the $10,000 CTR threshold.
Question 5: Under the USA PATRIOT Act, banks must implement a Customer Identification Program (CIP) verifying identity for which customers?
- Only commercial business accounts
- Only accounts with balances over $50,000
- All new account holders (Correct answer)
- Only non-US citizens
Correct answer: All new account holders
CIP requirements apply to all new account holders regardless of account type or balance.
Question 6: Which BSA/AML program element requires banks to understand the nature and purpose of customer relationships?
- Currency Transaction Reporting
- Customer Due Diligence (CDD) (Correct answer)
- Office of Foreign Assets Control screening
- Monetary Instrument Log
Correct answer: Customer Due Diligence (CDD)
Customer Due Diligence rules require banks to understand customer relationships to assess risk and detect unusual activity.
CRCM Bank Secrecy Act and Anti-Money Laundering 1
Under the Bank Secrecy Act, financial institutions must file a Currency Transaction Report (CTR) for cash transactions exceeding what threshold?