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CFDIC EXAMINATION COMPLETE
QUESTIONS AND DETAILED SOLUTIONS
LATEST UPDATE 2026 — JUST RELEASED
SECTION 1: BANK SECRECY ACT (BSA) & ANTI-MONEY LAUNDERING (AML)
FRAMEWORK (31 CFR 1020, SAR, CTR)
Questions 1–14
Q1: A depository institution is required to establish a written AML program under
the Bank Secrecy Act. Which of the following is NOT one of the five mandatory
pillars of the AML program as required by 31 CFR 1020.210?
A. Designation of a compliance officer responsible for day-to-day BSA/AML
compliance
B. Annual independent testing of the AML program by the institution's internal
audit department
C. Ongoing employee training programs tailored to specific job functions
D. Implementation of a customer identification program (CIP) as a separate
standalone requirement
Correct Answer: D
Rationale: Correct because the five mandatory AML program pillars are: (1)
internal controls, (2) independent testing, (3) designated compliance officer, (4)
employee training, and (5) risk-based CDD procedures. The CIP is integrated into
the CDD pillar, not a standalone pillar requirement.
Q2: Under 31 CFR 1020.311, a financial institution must file a Currency
Transaction Report (CTR) for each deposit, withdrawal, exchange of currency, or
other payment or transfer by, through, or to the institution that involves a
transaction in currency of more than:
A. $5,000
B. $10,000
C. $25,000
D. $50,000
Correct Answer: B
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Rationale: Correct because 31 CFR 1010.311 requires filing a CTR for any
currency transaction exceeding $10,000 in a single business day by or on behalf
of the same person.
Q3: A bank teller observes a customer conducting multiple cash deposits of
$9,500 each at three different branches of the same bank on the same business
day. The teller should recognize this activity as a potential violation of:
A. The Currency Transaction Report exemption rules
B. The structuring prohibition under 31 USC 5324
C. The Customer Identification Program requirements
D. The Office of Foreign Assets Control blocking requirements
Correct Answer: B
Rationale: Correct because 31 USC 5324 prohibits structuring transactions to
evade CTR filing requirements; multiple deposits just below the $10,000 threshold
designed to avoid reporting constitute structuring.
Q4: A Suspicious Activity Report (SAR) filed by a depository institution under 31
CFR 1020.320 must be filed within what timeframe after the date of initial
detection of facts that may constitute a basis for filing?
A. 15 calendar days
B. 30 calendar days
C. 45 calendar days
D. 60 calendar days
Correct Answer: B
Rationale: Correct because FinCEN regulations require SARs to be filed no later
than 30 calendar days after the date of initial detection of suspicious activity, with
a 60-day extension available for continuing suspicious activity exceeding $5,000.
Q5: Under 31 USC 5318(g), a financial institution and its directors, officers,
employees, and agents are prohibited from notifying which party that a SAR has
been filed?
A. The board of directors
B. Federal law enforcement agencies
C. The person involved in the suspicious activity
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D. The institution's primary federal regulator
Correct Answer: C
Rationale: Correct because 31 USC 5318(g) imposes a strict prohibition on
disclosing SAR filing to the subject of the report; this confidentiality provision is
central to BSA enforcement.
Q6: A bank compliance officer is reviewing whether to file a SAR for a series of
wire transfers totaling $18,000 that appear to lack a business or apparent lawful
purpose. Under 31 CFR 1020.320, what is the minimum aggregate dollar threshold
that triggers a SAR filing obligation for depository institutions?
A. $2,000
B. $5,000
C. $10,000
D. $25,000
Correct Answer: B
Rationale: Correct because 31 CFR 1020.320 requires depository institutions to
file a SAR for transactions aggregating $5,000 or more where the institution
knows, suspects, or has reason to suspect the transaction involves funds derived
from illegal activity or is designed to evade BSA requirements.
Q7: A Money Services Business (MSB) files a SAR for a transaction involving
$3,500 in currency that the MSB suspects is related to money laundering. Under
FinCEN regulations, what is the SAR filing threshold specifically for MSBs?
A. $1,000
B. $2,000
C. $5,000
D. $10,000
Correct Answer: B
Rationale: Correct because FinCEN regulations establish a $2,000 SAR filing
threshold for MSBs, which is lower than the $5,000 threshold applicable to
depository institutions, reflecting the higher risk profile of MSB transactions.
Q8: Which of the following records must a bank maintain for five years under BSA
recordkeeping requirements per 31 CFR 1010.430?
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A. Copies of all deposit slips for transactions under $1,000
B. Records of each extension of credit in amounts of $10,000 or more
C. Signature cards for all accounts opened after 2001
D. Monthly account statements for all checking accounts
Correct Answer: B
Rationale: Correct because 31 CFR 1010.430 requires banks to maintain records
of each extension of credit in amounts of $10,000 or more for five years, along
with other specified monetary instrument and funds transfer records.
Q9: A compliance officer discovers that a customer has been making regular cash
deposits of exactly $9,900 at multiple branches over a six-month period. The
officer suspects the customer is attempting to evade CTR reporting. Which
federal statute specifically criminalizes this conduct?
A. 18 USC 1956 (Money Laundering)
B. 31 USC 5324 (Structuring Transactions to Evade Reporting)
C. 31 USC 5318(a)(2) (BSA Program Requirements)
D. 18 USC 1001 (False Statements)
Correct Answer: B
Rationale: Correct because 31 USC 5324 specifically criminalizes structuring
transactions to evade BSA reporting requirements; the pattern of deposits just
below the $10,000 threshold demonstrates classic structuring behavior.
Q10: Under the BSA, a bank is required to retain records of funds transfers of
$3,000 or more for a minimum period of:
A. Three years
B. Five years
C. Seven years
D. Ten years
Correct Answer: B
Rationale: Correct because 31 CFR 1010.410 and 1010.430 require financial
institutions to maintain records of funds transfers of $3,000 or more for five years
from the date of the transfer.
CFDIC EXAMINATION COMPLETE
QUESTIONS AND DETAILED SOLUTIONS
LATEST UPDATE 2026 — JUST RELEASED
SECTION 1: BANK SECRECY ACT (BSA) & ANTI-MONEY LAUNDERING (AML)
FRAMEWORK (31 CFR 1020, SAR, CTR)
Questions 1–14
Q1: A depository institution is required to establish a written AML program under
the Bank Secrecy Act. Which of the following is NOT one of the five mandatory
pillars of the AML program as required by 31 CFR 1020.210?
A. Designation of a compliance officer responsible for day-to-day BSA/AML
compliance
B. Annual independent testing of the AML program by the institution's internal
audit department
C. Ongoing employee training programs tailored to specific job functions
D. Implementation of a customer identification program (CIP) as a separate
standalone requirement
Correct Answer: D
Rationale: Correct because the five mandatory AML program pillars are: (1)
internal controls, (2) independent testing, (3) designated compliance officer, (4)
employee training, and (5) risk-based CDD procedures. The CIP is integrated into
the CDD pillar, not a standalone pillar requirement.
Q2: Under 31 CFR 1020.311, a financial institution must file a Currency
Transaction Report (CTR) for each deposit, withdrawal, exchange of currency, or
other payment or transfer by, through, or to the institution that involves a
transaction in currency of more than:
A. $5,000
B. $10,000
C. $25,000
D. $50,000
Correct Answer: B
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Rationale: Correct because 31 CFR 1010.311 requires filing a CTR for any
currency transaction exceeding $10,000 in a single business day by or on behalf
of the same person.
Q3: A bank teller observes a customer conducting multiple cash deposits of
$9,500 each at three different branches of the same bank on the same business
day. The teller should recognize this activity as a potential violation of:
A. The Currency Transaction Report exemption rules
B. The structuring prohibition under 31 USC 5324
C. The Customer Identification Program requirements
D. The Office of Foreign Assets Control blocking requirements
Correct Answer: B
Rationale: Correct because 31 USC 5324 prohibits structuring transactions to
evade CTR filing requirements; multiple deposits just below the $10,000 threshold
designed to avoid reporting constitute structuring.
Q4: A Suspicious Activity Report (SAR) filed by a depository institution under 31
CFR 1020.320 must be filed within what timeframe after the date of initial
detection of facts that may constitute a basis for filing?
A. 15 calendar days
B. 30 calendar days
C. 45 calendar days
D. 60 calendar days
Correct Answer: B
Rationale: Correct because FinCEN regulations require SARs to be filed no later
than 30 calendar days after the date of initial detection of suspicious activity, with
a 60-day extension available for continuing suspicious activity exceeding $5,000.
Q5: Under 31 USC 5318(g), a financial institution and its directors, officers,
employees, and agents are prohibited from notifying which party that a SAR has
been filed?
A. The board of directors
B. Federal law enforcement agencies
C. The person involved in the suspicious activity
,3
D. The institution's primary federal regulator
Correct Answer: C
Rationale: Correct because 31 USC 5318(g) imposes a strict prohibition on
disclosing SAR filing to the subject of the report; this confidentiality provision is
central to BSA enforcement.
Q6: A bank compliance officer is reviewing whether to file a SAR for a series of
wire transfers totaling $18,000 that appear to lack a business or apparent lawful
purpose. Under 31 CFR 1020.320, what is the minimum aggregate dollar threshold
that triggers a SAR filing obligation for depository institutions?
A. $2,000
B. $5,000
C. $10,000
D. $25,000
Correct Answer: B
Rationale: Correct because 31 CFR 1020.320 requires depository institutions to
file a SAR for transactions aggregating $5,000 or more where the institution
knows, suspects, or has reason to suspect the transaction involves funds derived
from illegal activity or is designed to evade BSA requirements.
Q7: A Money Services Business (MSB) files a SAR for a transaction involving
$3,500 in currency that the MSB suspects is related to money laundering. Under
FinCEN regulations, what is the SAR filing threshold specifically for MSBs?
A. $1,000
B. $2,000
C. $5,000
D. $10,000
Correct Answer: B
Rationale: Correct because FinCEN regulations establish a $2,000 SAR filing
threshold for MSBs, which is lower than the $5,000 threshold applicable to
depository institutions, reflecting the higher risk profile of MSB transactions.
Q8: Which of the following records must a bank maintain for five years under BSA
recordkeeping requirements per 31 CFR 1010.430?
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A. Copies of all deposit slips for transactions under $1,000
B. Records of each extension of credit in amounts of $10,000 or more
C. Signature cards for all accounts opened after 2001
D. Monthly account statements for all checking accounts
Correct Answer: B
Rationale: Correct because 31 CFR 1010.430 requires banks to maintain records
of each extension of credit in amounts of $10,000 or more for five years, along
with other specified monetary instrument and funds transfer records.
Q9: A compliance officer discovers that a customer has been making regular cash
deposits of exactly $9,900 at multiple branches over a six-month period. The
officer suspects the customer is attempting to evade CTR reporting. Which
federal statute specifically criminalizes this conduct?
A. 18 USC 1956 (Money Laundering)
B. 31 USC 5324 (Structuring Transactions to Evade Reporting)
C. 31 USC 5318(a)(2) (BSA Program Requirements)
D. 18 USC 1001 (False Statements)
Correct Answer: B
Rationale: Correct because 31 USC 5324 specifically criminalizes structuring
transactions to evade BSA reporting requirements; the pattern of deposits just
below the $10,000 threshold demonstrates classic structuring behavior.
Q10: Under the BSA, a bank is required to retain records of funds transfers of
$3,000 or more for a minimum period of:
A. Three years
B. Five years
C. Seven years
D. Ten years
Correct Answer: B
Rationale: Correct because 31 CFR 1010.410 and 1010.430 require financial
institutions to maintain records of funds transfers of $3,000 or more for five years
from the date of the transfer.
