Certified Regulatory Compliance Manager (CRCM) — Question 241

State National Bank is a $250 million community bank. It makes a variety of consumer and commercial loans, regularly transmits funds via wire transfers for its customers, and issues commercial and stand-by letters of credit. Which of the following transactions can State National make without checking the OFAC SDN list and without incurring liability?

Answer options

• A. Send a wire transfer via its correspondent bank in New York for a commercial customer.
• B. Sell a cashier's check payable to a third party.
• C. Cash an on-us check over-the-counter for a noncustomer.
• D. None. The bank can be liable for all.

Correct answer: D

Explanation

The correct answer is D because State National Bank could incur liability for all the transactions listed if they fail to check the OFAC SDN list. Each option presents a scenario where the bank might unknowingly engage in a prohibited transaction, thus exposing itself to compliance risks.