RCC Anti-Money Laundering, Sanctions, and Financial Crimes Compliance

Question 1

Which sequence correctly describes the three classic stages of money laundering?

Accepted Answer

Placement, layering, integration

Answer

Money laundering typically begins with placement (introducing illicit cash into the financial system), then layering (moving funds through transactions to obscure their origin), and ends with integration (returning the funds to the economy as seemingly legitimate wealth).

Question 2

Under U.S. Bank Secrecy Act rules, a Currency Transaction Report (CTR) generally must be filed for cash transactions exceeding what amount in a single business day?

Accepted Answer

$10,000

Answer

Financial institutions must file a CTR for cash transactions (aggregated per person per business day) of more than $10,000. Breaking up transactions to avoid this threshold is itself an offense called structuring.

Question 3

A customer deposits $9,500 in cash on each of five consecutive days, apparently to stay below the reporting threshold. What is this behavior called, and what is the appropriate compliance response?

Accepted Answer

Structuring; escalate for review and consider filing a Suspicious Activity Report

Answer

Deliberately splitting cash deposits to avoid CTR reporting is structuring, which is a crime regardless of whether the funds are legitimate. Compliance staff should escalate the pattern and consider filing a SAR. They must not tip off the customer.

Question 4

In the U.S., within how many calendar days of initial detection of facts that may constitute a reportable suspicious activity must a financial institution generally file a SAR, if a suspect has been identified?

Accepted Answer

30 days

Answer

FinCEN rules generally require a SAR to be filed within 30 calendar days of initial detection of facts that may constitute a basis for filing. The deadline can extend to 60 days if no suspect has been identified.

Question 5

Which statement best describes civil liability for violations of OFAC sanctions regulations?

Accepted Answer

Liability is generally strict, so a violation can be penalized even without knowledge or intent

Answer

OFAC civil enforcement is based on strict liability. U.S. persons can be penalized for sanctions violations even if they did not know the transaction was prohibited. A risk-based sanctions compliance program is the main mitigating factor.

(RCC) Regulatory Compliance Certification Practice Test

(RCC) Regulatory Compliance Certification Practice Test

RCC Anti-Money Laundering, Sanctions, and Financial Crimes Compliance