American Bankers Association Exam CRCM Topic 8 Question 84 Discussion

Actual exam question for American Bankers Association's Certified Regulatory Compliance Manager exam

Question #: 84
Topic #: 8

[All Certified Regulatory Compliance Manager 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?

AReview the OFAC wire policies and procedures to determine how the errors occurred

BStop and hold all wires to the bank on the SDN list

CInvestigate the customer who sends these wires

DSelf-report the activity to OFAC

Show Suggested Answer

Suggested Answer: B

by Shonda at Apr 10, 2024, 08:45 PM

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Matthew

10 days ago

You know, option B about stopping and holding all the wires seems like a no-brainer. We can't just keep letting those payments go through to a bank on the SDN list, that's a big no-no.

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Isadora

12 days ago

Nah, I don't buy it. The bank's the one that messed up, so we need to own up to it. I say we go with option D and just get it over with.

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Daniela

13 days ago

Hold up, are we even sure the customer who's sending the wires is involved? Maybe we should investigate them first, like option C says. They could be totally innocent in all this.

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Franklyn

14 days ago

I don't know, man. Self-reporting could paint a big target on our backs. What if OFAC decides to make an example out of us? I'm leaning more towards reviewing the policies and procedures first, like option A suggests.

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Eric

16 days ago

I'm thinking option D, self-reporting to OFAC, is the way to go. It shows we're being proactive and taking responsibility for the screw-up. Plus, they might go easy on us if we come clean.

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Noel

18 days ago

Whoa, this is a tough one! The bank really messed up big time with that OFAC interdiction software glitch. We've got to act fast to mitigate the penalties, but which option is the best way to go about it?

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