Banking CRCM Exam
CERTIFIED REGULATORY COMPLIANCE MANAGER (CRCM) (Page 49 )

Updated On: 11-Jan-2026

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?

  1. The bank is already in compliance because OFAC checks are performed on all new depositors
  2. The bank has assessed its OFAC risk and has implemented risk-based OFAC procedures
  3. OFAC does not apply because the bank does not conduct business in foreign countries or with foreign nationals
  4. Banks are usually not fined for OFAC violations unless they conduct transactions with SDNs or blocked countries

Answer(s): B



When does a gift accepted by a banker clearly violate the Bank Bribery Act?

  1. When it is given for personal reasons
  2. When it is given with corrupt intent
  3. When it is valued at a dollar amount exceeding $50
  4. When it is not given in connection with a generally accepted holiday

Answer(s): B



Which of the following factors would NOT be considered when evaluating whether specific behavior by a banker violates the statute?

  1. The social and family ties of the banker
  2. The standard for business amenities and entertaining in that particular part of the country
  3. Whether there was a demonstrable business purpose
  4. Whether a business transaction was consummated as a result

Answer(s): D



Martin Taylor, a loan officer at First National Bank, is a long-time friend of Bill Evans, a local homebuilder. Bill would like a line of credit at the bank and discusses the potential loan with Martin. During the discussion, Martin expresses his desire to build a house one day and Bill offers to build him one "at cost plus 5 percent." If Martin accepts Bill's offer, can he continue to act as his loan officer?

  1. No. The value of the gift is too great.
  2. Yes, if Martin discloses this fact to the bank.
  3. Yes, if Martin does not let the discount on the house affect his decision making process.
  4. Yes, if the bank's code of conduct allows such activity.

Answer(s): A



Harvey Smith is a loan officer at First National Bank. Which of the following of Harvey's outside business interests may be considered to be a conflict of interest that should be disclosed to the bank?

  1. His ownership of 4,000 shares of stock in a local car dealership (the car dealership is not a bank customer)
  2. His wife's position as chair of the board of a local bank
  3. His attendance at a party hosted by one of his customers where other financial institutions were represented
  4. His role as honorary chair of a fund drive for a local charitable organization

Answer(s): B



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