Penalties
True or False: Civil penalties for individuals can range from $10,000 to $100,000 per violation.
What is True?
Who must comply with OFAC regulations?
Who are all U.S. persons and businesses? This includes U.S. citizens and permanent residents, as well as all individuals and entities within the United States, including banks, credit unions, and other financial institutions.
BSA/AML stands for what?
What Bank Secrecy Act and Anti-Money Laundering?
Fill in the blank: A SAR must be completed in its ____________.
What is Entirety?
True or False: Factors that influence penalties include the nature and seriousness of the violation, history of violations, the pervasiveness of wrongdoing within the institution, and management's involvement.
What is True?
The division of Department of Treasury that administers and enforces economic trade sanctions.
What is OFAC?
This regulations is to prevent financing for international and domestic terrorism.
What is US PATRIOT ACT OR Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism?
The Board of Directors receive SARS updates how often
What is monthly if reported?
Examples of Financial Institutions violating the Bank Secrecy Act (BSA).
What are structuring transactions, failure to file required reports (CTRs & SARs), knowingly facilitating illicit activities (assisting in structuring, accepting transactions without proper customer due diligence) or failing to not have a written BSA/AML compliance program.
Violating OFAC can include fines up to and how much prison time.
What are civil fines up to $356,579.00 per violation (or more, depending on the program) and criminal penalties may include up to $1 million and up to 20 years in prison.
The BSA/AML regulations apply to whom.
Who are banks, credit unions and digital currency markets.
There are 5 reportable offenses under SARs.
What are: 1) Insider Abuse (regardless of amount), 2) Violation of $5K or more when suspect is known, 3) Violation of $25K or more regardless of suspect, 4) Transactions of $5K or more potentially involving money laundering or BSA violations and 5) Transactions of $5K or more that lack a clear business or unlawful purpose and remain unexplained after investigation.
True or False: Under Criminal Penalties, individuals, including bank employees, who willfully violate the BSA or its regulations may face a criminal fine of up to $250,000 or five years in prison, or both.
What is True?
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?
Who is responsible at the National level for implementing rules and monitoring for compliance the Bank Secrecy Act.
Who is FinCEN? (Financial Crimes Enforcement Network)
The credit union is protected under this rule for filing a SAR.
What is "Safe Harbor"?
Banking regulators can impose penalties ranging from what to what?
What is $5,000 per violation up to $1,000,000 or 1% of the assets of a financial institution, whichever is greater, for every day the violation occurs?
What is the SDN and why is it important?
What is a list of individuals and entities that are blocked due to their association with targeted countries, terrorism, drug trafficking, or other prohibited activities? SDN is the Specially Designated Nationals list.
Amendments added to BSA has adjust to cover terrorist financing and what else?
What are money laundering and other illegal financial activities, such as forgery, counterfeiting, identity theft, fraud, and tax evasion , embezzlement and even financial exploitation?
These are the five essential items in which a SAR must identify.
What are: Who, What, Where, When and Why?
A member conducts multiple cash transactions throughout a single business day at different branches of the same financial institution, and each transaction is under $10K but the total exceeds $10K, is a CTR required? Explain.
What is yes. According to the Bank Secrecy Act and FinCEN guidelines, multiple cash transactions conducted by or on behalf of the same person that aggregate to more than $10K in a single business day must be entered as a single transaction for CTR reporting purposes.