Certified Regulatory Compliance Manager (CRCM) — Question 221

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?

Answer options

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

Correct answer: C

Explanation

The correct answer is C, as the total amount of counterfeit money discovered is less than $25,000, which does not meet the threshold for mandatory reporting. Options A and B incorrectly suggest that she must report and name individuals, which is unnecessary without suspicion of involvement. Option D is misleading since the overall amount is the deciding factor, not the individual incidents.