Regulatory Compliance and Bank Secrecy Act
The Regulatory Compliance and Bank Secrecy Act domain tests the teller's role in anti-money-laundering controls, customer due diligence, and currency reporting. Expect questions on CIP, CTRs, SARs, OFAC screening, structuring, recordkeeping, and confidentiality.
Core rules
- CIP: before opening an account, collect name, date of birth, address, and identification number; verify identity using documentary or non-documentary methods; retain records.
- CTR: file FinCEN Form 112 for currency transactions over $10,000 by or for one person in one business day, including multiple transactions that aggregate. File within 15 calendar days; do not tell the customer.
- SAR: file FinCEN Form 111 for suspicious activity at or above the applicable threshold, generally $5,000 for money laundering or BSA/structuring; file within 30 calendar days after detection, or 60 if no suspect is identified; never disclose the filing.
- Structuring: customers cannot break up cash transactions to avoid the $10,000 threshold. Do not suggest splitting a deposit.
- OFAC: screen names against SDN lists; block and report prohibited transactions rather than processing and releasing them.
- Monetary instruments: record cash purchases of money orders, cashier's checks, and traveler's checks between $3,000 and $10,000 under recordkeeping rules.
Worked example
A customer deposits $6,000 cash at 10 a.m. and another $6,000 at 2 p.m. Same person, same business day, so the total is $12,000 and a CTR is required. Do not suggest waiting until tomorrow. Verify identity, complete the record, and submit the report. If the pattern suggests deliberate avoidance, escalate as potential structuring.
Traps that cost marks
Counting only one transaction, filing a CTR on check deposits, telling a customer a report was filed, and ignoring structuring are frequent errors.