Question 1: How often does Zil Money conduct internal audits of its OFAC compliance program?
A) Monthly
B) Quarterly
C) Annually or more frequently if required
D) Every two years
Answer: C) Annually or more frequently if required
Question 2: What is the minimum record retention period for OFAC-related records at Zil Money? A) 3 years B) 5 years C) 7 years D) 10 years
Answer: B) 5 years
Question 3: When must new employees receive OFAC training? A) Within the first month B) Within the first week on the job C) Within 90 days D) Before the end of their probation period
Answer: B) Within the first week on the job
Question 4: What action may the Company take when OFAC matches are identified? A) Only monitor the transactions B) Block transactions and report them to OFAC C) Allow transactions to proceed with documentation D) Transfer responsibility to the customer
Answer: B) Block transactions and report them to OFAC
Question 5: What information must be collected for individual customers during account opening? A) Only name and address B) Name, address, and phone number C) Name, address, date of birth, and identification numbers D) Only government-issued ID
Answer: C) Name, address, date of birth, and identification numbers
Question 6: How long are customer identification records maintained after an account is closed? A) 3 years B) 5 years C) 7 years D) Permanently
Answer: B) 5 years
Question 7: What screening tool does Zil Money use for customer onboarding? A) Manual review only B) Persona C) Third-party banks D) Government databases only
Answer: B) Persona
Question 8: For corporate customers, what additional verification is required under AML regulations? A) Business registration only B) Financial statements C) Identification and verification of beneficial owners D) Board resolutions
Answer: C) Identification and verification of beneficial owners
Question 9: What must be filed when reporting suspicious activity to FinCEN? A) Currency Transaction Reports (CTRs) B) Suspicious Activity Reports (SARs) C) OFAC Violation Reports D) AML Compliance Reports
Answer: B) Suspicious Activity Reports (SARs)
Question 10: Which of the following is considered suspicious activity? A) Large legitimate business transactions B) Transactions involving OFAC sanctioned individuals C) Regular monthly payments D) Documented wire transfers
Answer: B) Transactions involving OFAC sanctioned individuals
Question 11: What is Zil Money's policy regarding retaliation against employees who report suspicious activity? A) Retaliation is permitted if the report is false B) Retaliation is strictly prohibited C) Retaliation is allowed with management approval D) No specific policy exists
Answer: B) Retaliation is strictly prohibited
Question 12: What does PEP stand for? A) Personal Electronic Payment B) Politically Exposed Persons C) Private Entity Protection D) Public Exchange Program
Answer: B) Politically Exposed Persons
Question 13: When is PEP screening performed? A) Only during customer onboarding B) Only annually C) During onboarding and on an ongoing basis D) Only when suspicious activity is detected
Answer: C) During onboarding and on an ongoing basis
Question 14: What additional step is required when a customer is identified as a PEP? A) Immediate account closure B) Enhanced due diligence C) Automatic OFAC reporting D) Increased transaction limits
Answer: B) Enhanced due diligence
Question 15: In what forms may compliance records be maintained? A) Original documents only B) Electronic format only C) Original, electronic, copy, or reproduction D) Hard copies with notarization
Answer: C) Original, electronic, copy, or reproduction
Question 16: What is the minimum retention period for BSA records including customer information and transaction monitoring records? A) 3 years B) 5 years C) 7 years D) 10 years
Answer: B) 5 years
Question 17: How often do existing employees receive OFAC compliance training? A) Monthly B) Quarterly C) Annually D) Every two years
Answer: C) Annually
Question 18: Which employees receive more frequent OFAC training? A) All employees equally B) Management only C) New employees only D) Employees in high-risk areas such as compliance and customer service
Answer: D) Employees in high-risk areas such as compliance and customer service
Question 19: What records are maintained for training sessions?
A) Attendance only
B) Topics covered only
C) Attendance, topics covered, and materials used
D) Just the training schedule
Answer: C) Attendance, topics covered, and materials used
Question 20: Who is responsible for ensuring appropriate compliance controls are in place for the CIP Program? A) All employees B) Chief Compliance Officer (CCO) C) Board of Directors D) External auditors
Answer: B) Chief Compliance Officer (CCO)
Question 21: What approach does Zil Money use for PEP screening? A) Standard approach for all customers B) Technology-only approach C) Risk-based approach D) Manual review only
Answer: C) Risk-based approach
Question 22: What happens if an employee violates OFAC policies? A) Verbal warning only B) Additional training required C) Disciplinary action including reprimands, suspension, termination, or legal action D) No consequences for first violations
Answer: C) Disciplinary action including reprimands, suspension, termination, or legal action
Question 23: What government watchlists does Zil Money screen against? A) OFAC SDN List only B) FBI Most Wanted List C) OFAC SDN List and other government watchlists D) State criminal databases
Answer: C) OFAC SDN List and other government watchlists
Question 24: How does Zil Money verify customer identity? A) Documentary methods only B) Non-documentary methods only C) Both documentary and non-documentary methods D) Third-party verification only
Answer: C) Both documentary and non-documentary methods
Question 25: What is required for customer identification documents? A) They can be expired if recently issued B) They must be unexpired and provide evidence of nationality/residence C) Any form of identification is acceptable D) Only passports are accepted
Answer: B) They must be unexpired and provide evidence of nationality/residence