Bank Secrecy Act Training (Round 2)

Abbreviation

100

CTR

What is Currency Transaction Report?

200

FinCen

What is Financial Crimes Enforcement Network?

300

SAR

What is Suspicious Activity Report?

400

CIP

What is Customer Identification Program?

500

OFAC

What is the Office of Foreign Assets Control?

OFAC

100

This person is CBNA's OFAC Officer

Who is Larry Witter?

200

The division of Department of Treasury that administers and enforces economic trade sanctions.

What is OFAC?

300

The primary purpose for OFAC.

What are administering economic trade sanctions against persons, entities and countries involved in state sponsored terrorism, drug trafficking, and the proliferation of weapons of mass destruction. 

400

All new customers are checked against one of these for CIP purposes.

What is Chex Systems or Credit Bureau Report? Both services are enhanced with OFAC check?

BI's BSA Policy

100

This is the dates that the board approved our BSA Policy.

What is January 28th & 29th, 2009 (occurs annually)?

200

These are the three different categories of risk assessment in our CIP Risk Assessment.

What are low, moderate and high?

300

This is the category in the risk assessment where the BSA officer or bank officer must okay the opening of an account.

What is high risk?

400

This is the category in the risk assessment where individuals may: ...seem to jump from bank to bank ...have hits on ChexSystems ...be a non-US person

What is Moderate Risk?

500

These are three of the six categories under the BSA Policy.

What are: Currency & Foreign Transaction Reporting Act Customer Due Diligence Policy Money Laundering Policy Officer of Foreign Asset Control (OFAC) Policy USA Patriot Act Section 314(a) Policy FinCen Customer Identification Policy

Common Types of Suspicious Activity

100

Numerous currency deposits in amounts just under the CTR reportable amount.

What is structuring?

200

Which of the following business types involved in heavy cash activity would be most suspicious and why?

a. Convenience store

b. Sports complex

c. Tax return preparation business

What is a tax return preparation business?

300

What type of criminal activity might a person be involved in who repeatedly brings in large amounts of $20s to exchange for $100s

What is drug dealing?

400

Which of the following activities is most suspicious. There may be more than one correct answer:

a. A person asked to exchange (5) $100s for $20s

b. A customer asks to deposit $12,000 cash. Upon being told by the teller that a CTR will need to be filed, the customer changes their mind and leaves the branch without completing the transaction.

c. A customer regularly deposits cash in an amount of $9,900.

What is b and c?

500

These are two of the five dollar limits for filing a SAR.

What are: 1) Suspected Insider Abuse: Report any amount. 2) Suspicious transactions where the bank has identified the suspect-report if amount is equal or greater than $5,000. 3) Suspicious transactions where the bank ahs not identified a suspect-report if amount equals or exceeds $25,000. 4) Known violations of the BSA-Report if amount equals or exceeds $5,000. 5) The BSA officer will file SARs for amounts less than those specified above, if he or she has reason to believe the transaction to an illegal activity as defined on the SAR.

Completing a CTR

100

This is the time frame for CTR record retention.

What is five years?

200

This is the form number for completing a CTR.

What is FINCEN form 104?

300

This is the CTR regulator or BSA Examiner.

Who is the Federal Reserve System FRS?

400

A person deposits $11,000 in currency to his savings account and withdraws $3,000 in currency from his checking account. How should the CTR be completed?

What is: Report the $11,000 cash in and no entry for the $3,000 cash out because it doesn't meet the reporting threshold?

500

A person deposits $11,000 in currency to his savings account and withdraws $12,000 in from his checking account. How should the CTR be completed?

What is: Report the cash in of $11,000 and cash out of $12,000 because both are reportable transactions? One CTR can be filed?