American Bankers Association Exam CRCM Topic 8 Question 84 Discussion

Actual exam question for American Bankers Association's CRCM exam

Question #: 84
Topic #: 8

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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Ailene

5 months ago

I think self-reporting the activity to OFAC should also be a priority, to show proactive efforts to rectify the situation.

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Glen

5 months ago

Should they stop and hold all wires to the bank on the SDN list immediately?

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Elliott

5 months ago

Yes, I agree. Understanding how the errors occurred is crucial.

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Venita

5 months ago

I think the BSA Officer should review the OFAC wire policies first, right?

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Ailene

5 months ago

Wow, that sounds like a serious situation

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Loren

5 months ago

I agree. Self-reporting to OFAC should also be considered to demonstrate cooperation.

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Luisa

6 months ago

But shouldn't we investigate the customer first to understand the situation better?

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Lacresha

6 months ago

Stopping all wires to the bank on the SDN list seems like a good plan.

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Lindy

6 months ago

I think reviewing the OFAC wire policies is crucial.

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Chi

7 months ago

We need to act quickly.

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Matthew

7 months 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

7 months 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

7 months 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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Whitley

6 months ago

We can investigate the customer while also reviewing our procedures.

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Reid

6 months ago

But what if the customer is involved somehow?

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Reynalda

6 months ago

I think we should review our OFAC wire policies first.

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Carin

6 months ago

We need to act fast. The wires have been going to a bank on the SDN list.

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Franklyn

7 months 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

7 months 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

8 months 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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