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Photo identification card issued by a local government agency
Which of the following customers may be exempted under Phase II of the Bank Secrecy Act?
Businesses whose stocks are traded on a national stock exchange
In which of the following circumstances is it LEAST appropriate for a bank to file a SAR regarding Internet activity?
Bank determines that one of its customers is the victim of identity theft
Bank becomes aware of identity theft of its domain name (i.e., another entity selects a name similar to the bank’s in order to confuse customers and obtain confidential financial information)
Bank discovers that someone has hacked into its data system in order to obtain
confidential customer data
Bank determines through its transaction-monitoring program that a customer is
making electronic transfers between his own checking and savings accounts that are just below the $10,000 reporting level
When completing and filing a SAR, what is the bank NOT required to do?
Submit a copy of the supporting documentation with the SAR
Submit the SAR within 30 days of the initial detection of facts
Report the SAR information to the bank’s board of directors
Maintain a copy of the SAR and supporting documentation for 5 years
What should a bank’s Bank Secrecy Act compliance program include?
All lobby notice requirements
The one-year record retention requirements
Designation of individuals responsible for day-to-day compliance
A list of types of loans covered by the Act
A routine review of account records reveals that suspicious activity involving foreign currency has occurred in the account of one of the bank’s directors. Which of the following actions should be taken FIRST?
A SAR should be filed.
The bank’s board of directors should discuss the account activity without the affected
director being present.
The bank’s president should meet with the affected director to discuss the account activity.
The bank should file a CTR, checking the box that indicates the report is for suspicious activity.
A compliance officer is constructing a review of a transaction in which M, a deposit
account customer, used cash to purchase travelers’ checks in an amount of $4,000. The compliance officer must determine compliance with financial recordkeeping and currency reporting regulations. Which of the following pieces of information must be part of the bank’s records for this transaction?
M’s date of birth
M’s deposit account number
The serial numbers of the travelers’ checks purchased
The name of the branch where the transaction occurred
When all the required information is NOT provided by a person purchasing a cashier’s check with $8,000 in currency, what should the bank do?
Refuse the transaction
Complete the transaction and record available information
Complete the transaction and file a SAR
Complete the transaction and insist that the customer return with the required information
Which of the following is MOST effective in strengthening an anti-money laundering
program involving cash transactions?
Review all deposits of $25,000 or more
Complete CTR worksheets on all cash transactions of $5,000 or more
Complete SAR worksheets on all cash transactions of $5,000 or more
Monitor cash transactions of less than $10,000 for suspicious patterns
For which of the following is a bank most likely to be in danger of receiving a cease and
Repetition in a BSA examination of a noncritical deficiency reported in a previous BSA examination
Failure to document AML training to its part-time clerical employees
A 2 percent error rate on the bank’s CTRs
Failure to file suspicious activity reports
Which of the following countries are currently subject to the Office of Foreign Assets
What should a bank do when it receives a request from a customer to transfer funds to an
individual in Iraq?
Conduct the transfer as requested
Conduct the transfer if the individual and the financial institution are not on the SDN
Block the transfer
Conduct the transfer and then notify OFAC immediately
ACME Bank is a $600 million institution with 15 branches within three counties. Because of its proximity to Mexico, the bank has many foreign national customers and makes many foreign wire transfers for its customers. Currently the bank’s branch managers print the OFAC list of SDNs and place them in strategic places in each branch. The wire transfer department keeps its own copy of the list. The compliance officer has implemented an annual auditing program to check the bank’s compliance with OFAC regulations. The findings of this audit are provided to the bank’s board of directors annually. The bank’s regulatory agency has indicated to management that the bank has a high risk for BSA/AML/OFAC compliance. Of the following actions, which would be the most effective to strengthen the bank’s OFAC compliance?
Conduct compliance audits twice a year
Purchase and implement interdiction software for the wire transfer area
As an internal control procedure, require the BSA officer to check the
OFAC Web site daily for any changes to the SDN list
Routinely provide account transaction information to federal security agencies so
suspicious patterns can be detected
State National Bank is a $250 million community bank. It makes a variety of consumer and commercial loans, regularly transmits funds via wire transfers for its customers, and issues commercial and stand-by letters of credit. Which of the following transactions can State National make without checking the OFAC SDN list and without incurring liability?
Send a wire transfer via its correspondent bank in New York for a commercial customer.
Sell a cashier’s check payable to a third party.
Cash an on-us check over-the-counter for a noncustomer.
None. The bank can be liable for all.
FA presents cash to the bank and seeks to wire it to his spouse, RA, in CubA. The OFAC list identifies RA as a specially designated national. Under OFAC Regulations, what should the bank do?
Block the transfer
Conduct the transfer as requested and take no further action
Conduct the transfer as requested and notify OFAC immediately
Conduct the transfer only if the bank determines that Cuba is not a blocked country
Your institution has identified a transaction by an existing depositor that should be
blocked under OFAC requirements. The branch manager contacts you for specific instructions. Before reporting the transaction to OFAC, what should the bank do?
Reject the transaction
Process the transaction
Close the customer’s account
Place the funds in an interest-bearing account
Your bank’s president comes back from an industry conference and tells the compliance officer that she attended a presentation about OFAC. She heard the bank could be fined for not adhering to OFAC requirements. Thus, she has directed that every bank transaction be reviewed for OFAC compliance. What is the most appropriate statement the compliance officer could make to the bank president?
The bank is already in compliance because OFAC checks are performed on all new depositors
The bank has assessed its OFAC risk and has implemented risk-based OFAC procedures
OFAC does not apply because the bank does not conduct business in foreign countries or with foreign nationals
Banks are usually not fined for OFAC violations unless they conduct transactions with SDNs or blocked countries
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?
Review the OFAC wire policies and procedures to determine how the errors occurred
Stop and hold all wires to the bank on the SDN list
Investigate the customer who sends these wires
Self-report the activity to OFAC
Banking CRCM Exam (Certified Regulatory Compliance Manager) Detailed Information
Certified Regulatory Compliance Manager (CRCM)
Make this the year you earn your Certified Regulatory Compliance Manager (CRCM) certification -- the recognized standard of excellence for regulatory compliance professionals working in the financial services area.
Earning this widely-respected certification lets your employer know that you have a formally-acknowledged level of knowledge, skills and competence in your field.
Interested in taking the next step toward your CRCM? Explore the following web pages to learn more about eligibility, exam requirements, and the pathway to earning your certification.
ABOUT THE CRCM
Path to the CRCM
Benefits of Certification
ABOUT THE EXAM
Outline & Knowledge Areas
Application, Dates & Fees
MAINTAIN YOUR CERTIFICATION
Maintain your CRCM
Certification Renewal Fee
Continuing Education Options
Approved ABA CE Options
Continuing Education FAQs
Login to the ICB Certification Manager
Certified Regulatory Compliance Manager (CRCM) Benefits
Take Your Career to the Next Level
Why pursue your CRCM designation? Consider these professional benefits and member values:
Career Enhancement — Earning the CRCM designation differentiates you from the competition and helps employers and clients identify you as a skilled, knowledgeable compliance manager. It's an industry gold standard that rewards your professional expertise.
Free Subscriptions — CRCMs enjoy free subscriptions to ABA Bank Compliance magazine (printed and electronic access, bimonthly, 6 issues per year) and ABA Regulatory & Legislative Advisory (electronic only, monthly, 12 issue per year).
CRCM Newsletter — You'll also receive the quarterly CRCM e-mail newsletter, which features program developments, member career notes, insights from ICB leadership, and the latest continuing education opportunities
Continuing Education (CE) Database — CRCMs can identify relevant professional development options quickly and easily with the members-only ICB Certification Manager, which highlights continuing education programs that have been approved for ICB credit,
Membership Directory — Access to the exclusive Membership Directory enables CRCMs to connect with peers who share their designation.
New Member Referral Incentives — Refer one person who applies for a certification exam in a given calendar year, and ICB will waive your certification renewal fee for the next calendar year, up to $249. Please use the ICB Member Referral Form.
CRCM Eligibility Requirements
Please note: The ICB certifications are based on U.S. laws and regulations and are therefore not offered outside the U.S.
Interested in exploring the CRCM designation? Learn whether you're eligible today! You must meet the following prerequisites to qualify to take the CRCM certification examination.
Professional Experience & Education
A minimum of three (3) years of U.S. experience as a compliance professional with primary responsibility for the full range of compliance functions is required. Compliance functions include (but are not limited to) performing compliance reviews and your ability to manage appropriate strategies to help the bank comply with U.S. federal laws and regulations; AND
A minimum of 80 credits of compliance-related training within the last five (5) years
Important Note: To satisfy the Professional Experience requirement, your job responsibilities must be focused primarily on bank legal and regulatory compliance requirements and internal policies. These jobs are typically found within corporate compliance, legal, or audit departments. Your job responsibilities must be primarily focused on compliance management:
• Program design, implementation and oversight,
• Consultation as a subject-matter expert, and/or
• Administration and enforcement of policies, procedures and processes to manage compliance risk
A compliance manager’s responsibilities generally include direct compliance risk program management and/or validation of compliance risk control effectiveness. The execution of operational business processes incorporating compliance risk controls is not a function or duty performed by a compliance manager as a normal and customary job responsibility and thus does not qualify towards meeting the experience requirement.
Training includes conferences, seminars, schools, online training and webinars that relate directly to the CRCM Examination Outline. These programs could be sponsored by your employer or an outside training provider in addition to ABA programs.
To calculate training credits when they are not listed, add the total minutes of instruction received -- minus meals and/or break times -- and divide that number by 50. Round up to the nearest quarter of an hour.
Following are examples of training that counts toward the 80 credits of required compliance-related training:
ABA National Compliance School -- Deposit Module (25 credits); Lending Module (30 credits); Management Module (4 credits)
ABA Intermediate Compliance School (30 credits)
ABA Graduate School of Compliance Risk Management (35 credits)
ABA Regulatory Compliance Conference (25 credits)
ABA Money Laundering Enforcement Conference (20 credits)
CRCM Online Review Course (30 credits)*
ABA Reference Guide to Regulatory Compliance, (30 credits)*
ABA Certificate in Deposit Compliance (15 credits)
ABA Certificate in Lending Compliance (33 credits)
ABA Training Courses
State Bankers Association Regulatory Compliance Schools and Training
*Candidates may only report a maximum of 30 credits for reviewing the ABA Reference Guide to Regulatory Compliance and/or completing the ABA Online Review Course for the CRCM Exam.
Each candidate must sign ICB's Professional Code of Ethics statement. Please note: you must furnish all pertinent information about any convictions or pleas of nolo contendere on the grounds of fraud, embezzlement, unfair or deceptive practices, securities law violations, misappropriation of property, fraudulent conversations or any civil or administrative action from which you have been previously found liable.
You must complete and submit the application. You are required to have met the eligibility requirements by the time that you take the exam. ICB will accept your application with education/training that is scheduled to be completed by your exam date.
CRCM Exam Overview
200 multiple-choice questions
Maximum 4 hour timeframe allowed
Calculators or other devices not permitted
Sample questions for the CRCM examination
ICB ensures that each question is complete, fair and measures only the required knowledge areas. Psychometricians and advisory board members ensure that each question is considered only when there is one right, clear answer and all cultural, geographical, organization biases and minute details eliminated. New questions are created and reviewed for relevance, content and difficulty by an exam development team comprised of advisory board members, ICB staff, and psychometricians.
Some questions may contain a superlative (i.e. MOST), a pejorative (i.e. LEAST), or a negative (i.e. NOT) to recreate some types of decisions that you may confront.
Exam Scoring and Reporting
The exam is scored on a "Pass/Fail" system using a predetermined cut off score based on advisory board analysis of the degree of difficulty for each question.
A preliminary instant pass/fail outcome is provided for computer based exams at testing centers.
Each exam contains a small number of randomly embedded questions that are included for statistical research purposes. These questions do not count against candidate scores. This form of piloting questions before they are scorable is part of ICB's efforts in continuous quality improvement.
Official score results are delivered for both computer based and paper and pencil exams within 4 weeks via email.
Exams are scored based on your personal performance and are not graded on a curve.
Score results are confidential. You must sign an Exam Score Release Form if you want to authorize a third party to receive your score results.
Effective January 2015, you must wait a minimum of 6 months before you are allowed to retake the CRCM exam on the next scheduled exam date.
You must forward the appropriate fee along with the exam retake form.
There is no limit to the number of times you can take the exam.
You must pass the exam within a 3 year period from the date of your first exam attempt or a new application and fee is required.
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Any person found to have violated any of the rules governing ICB certification exams, or to have conducted themselves in a dishonest or unethical manner with respect to the taking of an ICB certification exam is subject to sanctions determined to be appropriate by ICB, in its sole discretion, including, but not limited to: denial of certification; denial of the right to take any or all ICB examinations. Answer sheets provided at paper/pencil testing sites determined, before grading, to have been completed by a person who has violated ICB examination rules will not be graded. ICB reserves the right to pursue any and all remedies available to it, including legal remedies, with respect to any violation of its examination rules against anyone who violated ICB's examination rules or aided another in violating these rules.
CRCM Exam Outline & Knowledge Areas
The CRCM advisory board has determined that a competent compliance professional's expertise includes the following knowledge areas. Please review the CRCM exam outline for more specifics.
CRCM Certified Regulatory Compliance Manager
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Test Code : CRCM
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Vendor Name : Banking
Q&A : 463 Real Questions
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Certified Regulatory Compliance Manager education
Compliance manager position Descriptions | CRCM Real Questions and VCE Practice Test
Compliance managers help employees understand their roles in regulatory compliance.
Compliance managers assist personnel understand their roles in regulatory compliance.
Comstock photographs/Comstock/Getty photos
Compliance managers ensure that their organizations be aware and comply with any legal guidelines or rules that practice to their type of business, such because the Sarbanes-Oxley Act or the HIPPA privacy Rule. They work essentially in industries which are heavily regulated, similar to fiscal services, healthcare, prescribed drugs and chemical substances. The median annual profits for compliance managers become $99,540 in 2011, in response to O*internet online.
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