Banking CRCM Exam
CERTIFIED REGULATORY COMPLIANCE MANAGER (CRCM) (Page 17 )

Updated On: 12-Jan-2026

Bob Jones, president of ACME bank, has had a banking relationship with Linda O'Reilly, a local real estate agent for several years. Ms. O'Reilly keeps most of her deposit accounts with ACME and also has had several personal loans there. Over a three-month time period, Ms. O'Reilly consistently (two or three times a week) brings to the bank a series of money orders in amounts ranging from $7,000 to $15,000, made payable to her in denominations of $1,000, and asks the teller to take them and issue one cashier's check payable to her. After this activity has continued for three months, Mr. Jones notices the frequency of cashier's checks issued to Ms. O'Reilly on a management report. It catches his attention because he does not know why Ms. O'Reilly would need this number of cashier's checks. On inquiry, the head teller explains the weekly transactions. Which of the following statements best describes Mr. Jones's responsibility?

  1. He should immediately file a SAR. There is no logical explanation for this activity.
  2. He should immediately file a CTR. Ms. O'Reilly is trying to evade the BSA currency transaction.
  3. He should ask Ms. O'Reilly why she is conducting these transactions and then determine whether to file a SAR.
  4. He is not required to do anything. Mr. Jones is well acquainted with this customer, and it is not illegal to purchase cashier's checks.

Answer(s): C



Martha Whitmire, the BSA Compliance Officer for First National Bank, is responsible for monitoring the bank's daily currency activity and wire transfers, for compliance with information retention and reporting requirements. Ms. Whitmire notices during her review on March 10 that, during the previous two weeks, a transaction occurred on the same account several times during the week. The activity appeared at one branch office as cash deposits in dollar amounts under the reporting thresholds. Ms. Whitmire discusses this activity with the branch manager and determines that this same deposit activity occurred several times during the previous six weeks. She then conducts a more extensive examination of the account's activity for several months and discovers that cash deposits were made at one branch office and purchases of bank cashiers checks were made by withdrawals from the same account at a different branch office. All withdrawals and purchases of cashier's checks were for the identical amount as the cash deposits.Which statement best describes Ms. Whitmire's responsibility?

  1. Complete a CTR for each of the cash activities at the branch office
  2. Make no report of the activities because the transactions were not discovered until after the 15-day reporting deadline
  3. Report the account activity to senior management for further review
  4. Report the account activity as suspicious account activity and recommend that a SAR be filed

Answer(s): D



In April Lillian Redmond, the teller supervisor for First National Bank, discovers five counterfeit $20 bills in several teller drawers. In May and in June she discovers two additional counterfeit $20 bills. She has no knowledge of criminal activity on the part of any of the bank's employees or customers. She does not suspect any particular person in this transaction. Which of the following statements is true?

  1. Ms. Redmond must report the counterfeit funds on a SAR and must name the most likely individual(s) on the report.
  2. Ms. Redmond must report the counterfeit funds on a SAR but is not required to name any individual(s) on the report.
  3. Ms. Redmond need not file a SAR on this incident because the total amount is less than $25,000.
  4. Ms. Redmond need not report this incident on a SAR because each incident is less than $5,000.

Answer(s): C



Mammoth Enterprises is a new customer to the bank. It is a wholly owned subsidiary of Mammoth Corporation. Which of the following statements, if true, would make Mammoth Enterprises an exempt customer at the bank?

  1. Mammoth Corporation is a London corporation, trading on the London Stock Exchange.
  2. Mammoth Corporation is a U.S. corporation with unlisted stock.
  3. Mammoth Corporation is a U.S. corporation trading on the American Stock Exchange.
  4. Mammoth Enterprises is a U.S. corporation primarily in the investment banking business.

Answer(s): C



Records that must be retained for deposit accounts include which of the following?

  1. Average daily balance
  2. Overdraft history
  3. All amounts of currency deposited or withdrawn
  4. Customer's TIN

Answer(s): D



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