Could You Pass This Compliance Trivia Test?

The correct answer is "All of the above" because Maniflo agents are required to comply with the Bank Secrecy Act (BSA), which mandates financial institutions to assist government agencies in detecting and preventing money laundering. They must also comply with the PATRIOT ACT, which aims to prevent terrorism financing and enhance national security. Additionally, Maniflo agents must adhere to relevant state laws and regulations governing their activities.

A Currency Transaction Report must always be filed for cash transactions that exceed $10,000. This report is required by the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury. It helps to monitor and prevent money laundering and other illegal financial activities. By reporting large cash transactions, authorities can track any suspicious or potentially criminal activities and ensure compliance with anti-money laundering regulations. Therefore, any cash transaction exceeding $10,000 triggers the requirement to file a Currency Transaction Report.

Structuring refers to the practice of breaking down large transactions into smaller ones to avoid detection or reporting requirements. In this case, customers are using multiple transactions to avoid providing proper identification, which aligns with the concept of structuring. Splitting and shifting do not accurately describe this behavior, and "None of the above" is not applicable since the correct answer is structuring.

A Suspicious Activity Report (SAR) will be filed anytime a transaction seems suspicious, regardless of the amount involved. This means that even if a transaction is below $3000 or $10,000, it will still be reported if it raises suspicions. The focus is on identifying and reporting any suspicious activity rather than solely basing it on the transaction amount.

The correct answer is "All of the above" because the statement suggests that agents must train employees on proper transaction policies and procedures in three different scenarios: whenever a new employee is hired, once a year after being hired, and when new regulations or policies are enacted. This indicates that training is necessary in all of these situations.

A transaction is considered suspicious when any of the mentioned scenarios occur. These scenarios include one customer sending multiple transmissions to one person on the same day, multiple customers sending funds to the same person on the same day, and a customer having multiple transactions to persons with similar names on the same day. All of these situations raise red flags and indicate potentially fraudulent or illicit activity.

The correct answer is "Never tell the customer a SAR has been filed." This is because disclosing the filing of a Suspicious Activity Report (SAR) to the customer could potentially compromise the investigation and alert the customer, which could result in them altering their behavior or attempting to evade detection. SARs are filed by financial institutions to report potentially suspicious transactions to the appropriate authorities, and it is important to maintain confidentiality to ensure the effectiveness of the reporting system.

This answer suggests that agents should not inform customers about the different levels of identification required for transactions of different amounts, and they should not advise customers to divide their transactions to avoid additional identification.

When an agent believes a transaction might be suspicious, it is important for them to complete the transaction first to avoid alerting the customer and potentially jeopardizing an investigation. However, they should also inform Maniflo's compliance department so that they can investigate further and take appropriate action if necessary. This ensures that the company is aware of any suspicious activity and can comply with legal and regulatory requirements. Refusing to complete the transaction or simply remembering the customer for next time may not address the potential risks involved. Therefore, the correct course of action is to complete the transaction and then inform the compliance department.

According to federal law, transactions of $3000 or more require additional identification. However, for transactions between $2000 and $2999, the customer still needs to provide ID. Therefore, the correct answer is that neither the customer's date of birth nor their occupation needs to be recorded if they claim to have no ID, as ID is still required for transactions of $2000.