Bank Secrecy Act (questions with
complete solutions) graded A+
Four (Five) Pillars of BSA Compliance - correct answer ✔✔1. Policies and procedures for recordkeeping
and reporting.
2. Training of appropriate personnel.
3. System of internal controls (audit procedures).
4. Designated Individual responsible for day to day compliance.
5. Effective late 2018, there is a beneficial owners component.
Currency Transaction Reporting (CTR) - correct answer ✔✔1. Cash Amounts (in or outbound) of MORE
THAN $10,000
2. By or for the same person
3. Made on the same day
must be reported (e-filed) within 15 days of the transaction.
Multiple transactions made by or for the same person must be aggregated to determine if the threshold
is met.
There must be dual control over the report - the person completing the form must be different from the
person who files it.
CTR Exemptions - correct answer ✔✔1. Other financial institutions.
2. Companies listed on an exchange.
3. Non-listed businesses who have a transaction account for more than 2 months, and who have 5 or
more qualifying deposits in a year.
4. must validate eligibility for exemption annually.
, Suspicious Activity Reporting (SAR) - correct answer ✔✔Required for:
1. any amount for insiders (employees, etc.)
2. $5,000 cash transaction if the individual is known.
3. $25,000 cash transaction if the individual is unknown.
4. Note: if the transaction is less than or equal to $10,000, then file SAR but CTR is not needed.
Other SAR attributes:
1. Activity is "suspicious" when it is out of the ordinary for a customer.
2. Document decisions to file as well as to not file.
3. Maintain the information for at least 5 years.
4. Do not tell a customer that you are filing an SAR.
Customer Due Diligence - correct answer ✔✔Customer Due Diligence means that banks can predict with
reasonable accuracy the typical behavior of customers. This aids in identifying suspicious activity.
Beneficial Ownership - correct answer ✔✔Reserved for later in 2018 (after the May CRCM exam)
Enhanced Due Diligence - correct answer ✔✔Designed for high risk customers. Requires additional
information at account opening and more frequently thereafter:
1. Purpose of the account.
2. Source of funds.
3. Customer's occupation/type of business.
4. Financial statements.
5. References.
6. Domicile.
7. Description of business operations, sales, major customer and suppliers.
Monetary Instrument Record - correct answer ✔✔A retrievable record when there is a purchase of a
monetary instrument (cashier's check, money order, traveler's check, bank draft, etc.) for $3,000 or
more.
complete solutions) graded A+
Four (Five) Pillars of BSA Compliance - correct answer ✔✔1. Policies and procedures for recordkeeping
and reporting.
2. Training of appropriate personnel.
3. System of internal controls (audit procedures).
4. Designated Individual responsible for day to day compliance.
5. Effective late 2018, there is a beneficial owners component.
Currency Transaction Reporting (CTR) - correct answer ✔✔1. Cash Amounts (in or outbound) of MORE
THAN $10,000
2. By or for the same person
3. Made on the same day
must be reported (e-filed) within 15 days of the transaction.
Multiple transactions made by or for the same person must be aggregated to determine if the threshold
is met.
There must be dual control over the report - the person completing the form must be different from the
person who files it.
CTR Exemptions - correct answer ✔✔1. Other financial institutions.
2. Companies listed on an exchange.
3. Non-listed businesses who have a transaction account for more than 2 months, and who have 5 or
more qualifying deposits in a year.
4. must validate eligibility for exemption annually.
, Suspicious Activity Reporting (SAR) - correct answer ✔✔Required for:
1. any amount for insiders (employees, etc.)
2. $5,000 cash transaction if the individual is known.
3. $25,000 cash transaction if the individual is unknown.
4. Note: if the transaction is less than or equal to $10,000, then file SAR but CTR is not needed.
Other SAR attributes:
1. Activity is "suspicious" when it is out of the ordinary for a customer.
2. Document decisions to file as well as to not file.
3. Maintain the information for at least 5 years.
4. Do not tell a customer that you are filing an SAR.
Customer Due Diligence - correct answer ✔✔Customer Due Diligence means that banks can predict with
reasonable accuracy the typical behavior of customers. This aids in identifying suspicious activity.
Beneficial Ownership - correct answer ✔✔Reserved for later in 2018 (after the May CRCM exam)
Enhanced Due Diligence - correct answer ✔✔Designed for high risk customers. Requires additional
information at account opening and more frequently thereafter:
1. Purpose of the account.
2. Source of funds.
3. Customer's occupation/type of business.
4. Financial statements.
5. References.
6. Domicile.
7. Description of business operations, sales, major customer and suppliers.
Monetary Instrument Record - correct answer ✔✔A retrievable record when there is a purchase of a
monetary instrument (cashier's check, money order, traveler's check, bank draft, etc.) for $3,000 or
more.
