Certified Regulatory Compliance Manager (CRCM) — Question 245

The BSA officer has just been notified by the chief operations officer that, due to a glitch in the bank's OFAC interdiction software, wires have been regularly transmitted to a bank on the SDN list. Based on the OFAC Enforcement Guidance, what should the BSA Officer do FIRST to attempt to mitigate any penalties?

Answer options

• A. Review the OFAC wire policies and procedures to determine how the errors occurred
• B. Stop and hold all wires to the bank on the SDN list
• C. Investigate the customer who sends these wires
• D. Self-report the activity to OFAC

Correct answer: B

Explanation

The correct action is to stop and hold all wires to the bank on the SDN list to prevent further violations while assessing the situation. Reviewing policies and investigating customers are important steps, but they should come after immediate action is taken to mitigate risk. Self-reporting is also essential, but the priority should be preventing additional transactions.