Certified Regulatory Compliance Manager (CRCM) — Question 204

Country A (a foreign country that is boycotting Country B, another foreign country) has ordered goods from ABC, a U.S. corporation. Country A has opened a letter of credit with Overseas, Inc., a foreign bank. The letter of credit specifies that ABC must certify that it does not do business with Country B. Overseas, Inc., sends a telegram to First National Bank, a U.S. bank, stating the major terms and conditions of the letter of credit and asking First National Bank to confirm the letter of credit. The telegram does not state the boycott provisions. Overseas mails the letter of credit to First National Bank and asks First National Bank to confirm it.
What may First National Bank do?

Answer options

• A. First National Bank must confirm it if it previously agreed to do so.
• B. First National Bank may advise ABC of the letter of credit and administer its disposal, but may not confirm it and must report it to the Department of Commerce and the IRS.
• C. First National Bank may do nothing but return the letter of credit to the issuing bank and report to the IRS.
• D. First National Bank must confirm the letter of credit but should also report it to the Department of Commerce.

Correct answer: B

Explanation

The correct answer is B because First National Bank can advise ABC and manage the letter of credit without confirming it due to the omission of the boycott provisions. Options A and D are incorrect as they imply a mandatory confirmation, which is not the case here. Option C is also wrong because it suggests no action other than returning the letter, which does not align with the bank's responsibilities in this situation.