CBT Teller Compliance and Regulations 2 — Questions and Answers
Question 1: A customer deposits $6,000 in cash in the morning and returns that afternoon to deposit another $5,000 in cash into the same account. What must the bank do?
- File a Currency Transaction Report because the cash deposits total more than $10,000 in one business day (Correct answer)
- Do nothing because each deposit is under $10,000
- File a CTR only if the customer asks for one
- Put a 30-day hold on the second deposit
Correct answer: File a Currency Transaction Report because the cash deposits total more than $10,000 in one business day
Banks must add up multiple cash transactions by or for the same person in one business day, and a total over $10,000 requires a CTR.
Question 2: Within how many calendar days after the transaction must a bank file a Currency Transaction Report with FinCEN?
- 5 days
- 15 days (Correct answer)
- 30 days
- 60 days
Correct answer: 15 days
A CTR must be filed electronically with FinCEN within 15 calendar days after the reportable transaction.
Question 3: A customer asks a teller how to split a $14,000 cash deposit so that 'no government form' gets filed. What is the best description of this request?
- A normal question about deposit limits
- Possible structuring, which may need to be reported on a Suspicious Activity Report (Correct answer)
- Allowed if the customer has a business account
- A matter for the customer's tax preparer only
Correct answer: Possible structuring, which may need to be reported on a Suspicious Activity Report
Breaking up cash transactions to avoid CTR reporting is structuring, a federal crime, and should be escalated for possible SAR filing.
Question 4: After a teller refers suspicious activity to the BSA officer, the customer asks whether the bank is 'reporting' them. What should the teller do?
- Confirm that a SAR is being filed so the customer knows
- Show the customer the SAR form
- Not disclose whether a SAR has been or will be filed (Correct answer)
- Tell the customer to call FinCEN
Correct answer: Not disclose whether a SAR has been or will be filed
Federal law bars bank employees from telling anyone involved in the transaction that a SAR has been filed or considered.
Question 5: Under the Bank Secrecy Act, cash purchases of which items between $3,000 and $10,000 must be recorded in a monetary instrument log?
- Bank checks, cashier's checks, money orders, and traveler's checks (Correct answer)
- Certificates of deposit only
- Savings bonds and stocks
- Prepaid debit cards only
Correct answer: Bank checks, cashier's checks, money orders, and traveler's checks
Banks must keep records of cash purchases of bank checks, cashier's checks, money orders, and traveler's checks from $3,000 to $10,000 inclusive.
Question 6: Before a teller completes a transaction for a non-customer, the name comes up as a possible match on the OFAC SDN list. What is the correct next step?
- Complete the transaction and note it later
- Stop the transaction and send it to the bank's OFAC or compliance officer for review (Correct answer)
- Ask the person whether they are on a sanctions list
- Close the person's account right away
Correct answer: Stop the transaction and send it to the bank's OFAC or compliance officer for review
A possible OFAC match must be held and escalated to compliance to confirm whether it is a true match before any action is taken.
Question 7: How long must BSA records such as CTRs and monetary instrument logs generally be kept?
- 1 year
- 3 years
- 5 years (Correct answer)
- 7 years
Correct answer: 5 years
The Bank Secrecy Act generally requires banks to keep these records for five years.
