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American Bankers Association CRCM Exam - Topic 10 Question 122 Discussion

The BSA officer has just been notified by the chief operations officer that, due to a glitch in the bank's OFAC interdiction software, wires have been regularly transmitted to a bank on the SDN list. Based on the OFAC Enforcement Guidance, what should the BSA Officer do FIRST to attempt to mitigate any penalties?
B) Stop and hold all wires to the bank on the SDN list
A) Review the OFAC wire policies and procedures to determine how the errors occurred
C) Investigate the customer who sends these wires
D) Self-report the activity to OFAC

American Bankers Association CRCM Exam - Topic 10 Question 122 Discussion

Actual exam question for American Bankers Association's CRCM exam
Question #: 122
Topic #: 10
[All CRCM Questions]

The BSA officer has just been notified by the chief operations officer that, due to a glitch in the bank's OFAC interdiction software, wires have been regularly transmitted to a bank on the SDN list. Based on the OFAC Enforcement Guidance, what should the BSA Officer do FIRST to attempt to mitigate any penalties?

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Suggested Answer: B

by Tegan at Mar 04, 2026, 09:01 AM

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Karma
9 hours ago
I feel like A is important too. Understanding the error is key.
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Curt
6 days ago
I think D is the best choice. Self-reporting shows transparency.
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Craig
11 days ago
I disagree, investigating the customer should come first!
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Cherrie
16 days ago
Wait, how did the software glitch even happen?
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Anthony
2 months ago
Self-reporting sounds risky, but maybe necessary?
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Junita
2 months ago
I think stopping the wires is the most important step!
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Cammy
2 months ago
Definitely need to review the OFAC policies first.
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Stevie
3 months ago
Not sure investigating the customer is the right move right now.
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Helga
3 months ago
Surprised this glitch happened in the first place!
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Leota
3 months ago
Self-reporting seems risky, but might be necessary.
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Aileen
3 months ago
I think stopping the wires is the most urgent step!
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Glenn
3 months ago
Definitely need to review the OFAC policies first.
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Julio
3 months ago
I think investigating the customer who sends the wires could be important, but it might not be the first thing to do. I feel like we need to address the software issue first.
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Francene
4 months ago
I remember a practice question where self-reporting was emphasized. It seems like a good option, but I wonder if we should investigate first to gather more information.
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Timmy
4 months ago
I’m not entirely sure, but I feel like stopping and holding all wires to the SDN bank might be the safest immediate action. We can't risk further violations, right?
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Anika
4 months ago
I think the first step should be to review the OFAC wire policies and procedures. It’s important to understand how the glitch happened before taking further action.
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