Larry Witter
Who is the Bank's BSA Officer?
The bank must maintain record for each bank check or draft, cashier's check, money order or traveler's check it sells or issues for this amount or more in cash.
What is $3,000?
When & why did the government enforce CIP?
October 2003. To help the government fight the funding of terrorism and money laundering activities.
True or False: It is permissible to notify a customer that a SAR is being filed on them.
What is False? It is a federal crime to notify any person that they are the subject of a SAR.
FIU Help Desk, BSAReporting@communitybankna.com or SharePoint.
What are various ways that bank employees can report suspicious activity or get support regarding BSA matters.
True or False: If a customer purchases a cashier's check for $2,000 and money orders totaling $1,500 on the same day, no record would be necessary because both amounts are below the $3,000 threshold.
What is False? Contemporaneous purchases of the same or different types of instruments totaling $3,000 or more must be treated as one purchase. Multiple purchases during one business day totaling $3,000 or more must be aggregated and treated as one purchase if the bank has knowledge that the purchases have occurred.
A person who owns 25% or more equity in a legal entity.
What is a beneficial owner?
Which of the following activities most requires further investigation.
a. A loan applicant refuses to discuss the purpose for the loan.
b. A loan applicant's stated purpose for the loan makes no sense.
c. A borrower with no prior wire activity begins transferring loan proceeds to foreign countries.
What is all require further investigation?
Tim Murphy
Who is the Assistant Bank Secrecy Act Officer?
The bank has this many calendar days after the "business day" the reportable cash transaction occurred to file a CTR online.
What is 15?
True or False: If a customer wants to purchase a monetary instrument with cash in an amount of $3,000 or more and the customer first deposits the cash to their deposit account, the information required for BSA record keeping does not need to be collected.
What is False? If the customer purchases monetary instrument(s) in amounts between $3,000 and $10,000 using currency that the customer first deposits into the customer’s account, the transaction is still subject to the recordkeeping requirements Generally, when a bank sells monetary instruments to deposit accountholders, the bank will already maintain most of the information required in the normal course of its business.
What are the 4 pieces of identifying information required to open an account?
1. Legal Name. 2. Date of Birth. 3. Physical Address. 4. Identifying Number.
Large currency deposits would make the least sense for which of the following businesses.
a. A grocery store.
b. A merchant that sells goods only on-line.
c. A convenience store.
What is (b)?
While opening an account, you receive a possible OFAC match that you cannot determine is a false positive. What should you do next?
What is call the FIU?
True or False: If a person purchases a cashier's check with cash in an amount greater than $10,000, a CTR does not need to be filed.
What is False?
Individuals, corporations, LLCs, associations, unincorporated groups.
What are some examples of a legal entities?
Name a foreign country that the US Government considers a bank secrecy haven.
What is The Cayman Islands, Bermuda, Bahamas, Singapore, Switzerland, Netherlands, BVI, Luxembourg, Hong Kong.
Cayman Islands
What country is the US Government's greatest concern for money laundering?
This is the name of the method of money laundering in which negotiable instruments were purchased for cash below the currency transaction reporting threshold.
What is structuring or smurfing?
True or False: For CIP compliance, a PO Box is an acceptable address in some cases.
What is False?
Choose the activity below that looks most like intentional cash structuring to avoid the filing of a CTR.
a. A personal customer has conducted (5) cash deposits in the past two weeks, each deposit in the amount of $9,900.
b. Every Monday, a business customer deposits cash in the amount of $12,000. Occasionally they make cash deposits during the week in the amount of $9,100.
c. Every Monday and Thursday at noon, a business customer makes a $5,000 deposit at branch #1 and a $5,000 deposit later in the day at branch #2.
What is (a)?