BSA/AML certification Exam with
Complete Solutions
Bank Secrecy Act - ANS-to assist law enforcement in the investigation and obstruction
of money laundering, terrorist financing, tax evasion, and other criminal activity
BSA/AML Compliance Program 5 Pillars - ANS-A qualified BSA compliance officer, a
system of internal controls, independent testing, training for all appropriate personnel,
ongoing member due diligence
Compliance programs must be... - ANS-In writing, approved by BOD, and reflected in
minutes of the board meeting
Qualified compliance officer - ANS-Appointed by BOD, expected to be knowledgeable
of BSA, money laundering & terrorist financing risks associated with credit union's risk
Credit union risk factors - ANS-products, services, members, and geographic locations
System of internal controls - ANS-Policies and procedures put in place to limit/control
risks,
Non-listed businesses 4 criteria for CTR exemption - ANS-maintained a transaction
account for at least 2 months (could be eligible if CU conducts risk based analysis),
frequently engage in reportable transactions (5 or more within a year), organized or
incorporated under US federal or state law, must not derive more than 50% of its gross
revenues from ineligible business activity
Businesses ineligible for CTR exemption - ANS-car dealers, pawnshops, race tracks,
real estate brokers, and others
Payroll members 3 criteria for CTR exemption - ANS-maintain a transaction account for
at least 2 months (could be eligible if CU conducts risk based analysis), operate a firm
that regularly WITHDRAWS more than 10k to pay it's employees in currency,
incorporated or organized under the federal or state law of the US
DOEP (Designation of exempt person) - ANS-must file a one-time DOEP with FinCEN
within 30 days after the first transaction that the CU wants to exempt, must be reviewed
annually
, When to file SAR - ANS-criminal violations involving insider abuse in any amount, $5k
or more with suspect, $25k or more suspect unknown, or $5k or more that may involve
illegal activity, designed to evade BSA regulations
SAR red flags - ANS-member uses suspicious identification documents that can't be
verified, member with no employment makes frequent or large transactions, structuring,
wire or EFT activity unexplained, new business account reluctant to provide info on
business, small incoming wires or deposits using checks and money orders and then
wired to another city or country
SAR filing deadlines - ANS-30 calendar days from detection, 30 extra to identify suspect
if unknown
SAR filing on continuing activity - ANS-90 day review period, with filing deadline 120
days after the date of previous SAR filing
Board notification of SAR filings - ANS-at least monthly
SAR record retention - ANS-five years from the date of the SAR filing including
supporting documents
SAR law enforcement requests procedures - ANS-should address identifying subjects of
law enforcement requests, monitoring the transaction activity of those subjects when
appropriate, identifying unusual suspicious activity related to the subjects, filing SARs
related to those subjects
SAR disclosure - ANS-able to disclose to FinCEN, an appropriate law enforcement
agency, or CU's regulators (not a law firm)
Law enforcement requests to maintain an account - ANS-Need written request
indicating agency that requested and purpose and duration. CUs should maintain
documentation for at least 5 years after the request has expired
True or false: CUs must maintain an account if requested by law enforcement - ANS-
False
314a - ANS-facilitates the sharing of info between financial institutions and the federal
government regarding individuals/entities/organizations suspected of engaging in
terrorist acts or money laundering activities
314b - ANS-permits financial institutions to share info with one another in order to better
identify and report activities that may involve money laundering or terrorist activities
314a allows... - ANS-a law enforcement agency to solicit info from a FI via a FinCEN
information request
Complete Solutions
Bank Secrecy Act - ANS-to assist law enforcement in the investigation and obstruction
of money laundering, terrorist financing, tax evasion, and other criminal activity
BSA/AML Compliance Program 5 Pillars - ANS-A qualified BSA compliance officer, a
system of internal controls, independent testing, training for all appropriate personnel,
ongoing member due diligence
Compliance programs must be... - ANS-In writing, approved by BOD, and reflected in
minutes of the board meeting
Qualified compliance officer - ANS-Appointed by BOD, expected to be knowledgeable
of BSA, money laundering & terrorist financing risks associated with credit union's risk
Credit union risk factors - ANS-products, services, members, and geographic locations
System of internal controls - ANS-Policies and procedures put in place to limit/control
risks,
Non-listed businesses 4 criteria for CTR exemption - ANS-maintained a transaction
account for at least 2 months (could be eligible if CU conducts risk based analysis),
frequently engage in reportable transactions (5 or more within a year), organized or
incorporated under US federal or state law, must not derive more than 50% of its gross
revenues from ineligible business activity
Businesses ineligible for CTR exemption - ANS-car dealers, pawnshops, race tracks,
real estate brokers, and others
Payroll members 3 criteria for CTR exemption - ANS-maintain a transaction account for
at least 2 months (could be eligible if CU conducts risk based analysis), operate a firm
that regularly WITHDRAWS more than 10k to pay it's employees in currency,
incorporated or organized under the federal or state law of the US
DOEP (Designation of exempt person) - ANS-must file a one-time DOEP with FinCEN
within 30 days after the first transaction that the CU wants to exempt, must be reviewed
annually
, When to file SAR - ANS-criminal violations involving insider abuse in any amount, $5k
or more with suspect, $25k or more suspect unknown, or $5k or more that may involve
illegal activity, designed to evade BSA regulations
SAR red flags - ANS-member uses suspicious identification documents that can't be
verified, member with no employment makes frequent or large transactions, structuring,
wire or EFT activity unexplained, new business account reluctant to provide info on
business, small incoming wires or deposits using checks and money orders and then
wired to another city or country
SAR filing deadlines - ANS-30 calendar days from detection, 30 extra to identify suspect
if unknown
SAR filing on continuing activity - ANS-90 day review period, with filing deadline 120
days after the date of previous SAR filing
Board notification of SAR filings - ANS-at least monthly
SAR record retention - ANS-five years from the date of the SAR filing including
supporting documents
SAR law enforcement requests procedures - ANS-should address identifying subjects of
law enforcement requests, monitoring the transaction activity of those subjects when
appropriate, identifying unusual suspicious activity related to the subjects, filing SARs
related to those subjects
SAR disclosure - ANS-able to disclose to FinCEN, an appropriate law enforcement
agency, or CU's regulators (not a law firm)
Law enforcement requests to maintain an account - ANS-Need written request
indicating agency that requested and purpose and duration. CUs should maintain
documentation for at least 5 years after the request has expired
True or false: CUs must maintain an account if requested by law enforcement - ANS-
False
314a - ANS-facilitates the sharing of info between financial institutions and the federal
government regarding individuals/entities/organizations suspected of engaging in
terrorist acts or money laundering activities
314b - ANS-permits financial institutions to share info with one another in order to better
identify and report activities that may involve money laundering or terrorist activities
314a allows... - ANS-a law enforcement agency to solicit info from a FI via a FinCEN
information request
