{ "question_text": "Why must the independent reviewer not report to the BSA/AML Compliance Officer?", "options": [ "Because the review checks the compliance officer's work, so routing through them would compromise the findings", "Because senior management is responsible for setting the scope of all reviews", "Because the BSA/AML Compliance Officer is not authorized to receive written review reports", "Because examiners require all reports to be submitted directly to the ownership" ], "correct_answer": "Because the review checks the compliance officer's work, so routing through them would compromise the findings", "correct_response": "Correct. The review is a check on the compliance program — which includes the BSA/AML Compliance Officer's work. Routing findings through the compliance officer would compromise the independence and objectivity of the review.", "incorrect_response": "The reviewer must not report to the BSA/AML Compliance Officer because the review is a check on the compliance program — which is the BSA/AML Compliance Officer's responsibility. Routing findings through them would compromise the independence of the review.", "unsure_response": null, "question_bank": [ { "question_text": "After problems are identified in the independent review, what must happen for each one?", "options": [ "An owner must be assigned and a deadline set to fix the problem", "The Florida licensing authority must be notified before any action is taken", "The reviewer decides who is responsible for fixing each problem", "Senior management waits for the BSA/AML Compliance Officer to propose a fix" ], "correct_answer": "An owner must be assigned and a deadline set to fix the problem", "correct_response": "Correct. For every problem found, senior management must assign an owner and set a deadline. The BSA/AML Compliance Officer then tracks those fixes and reports status at each compliance reporting cycle until every item is closed.", "incorrect_response": "For every problem identified in the review, senior management must assign an owner and set a deadline to fix it. The BSA/AML Compliance Officer tracks those fixes and reports on them until every item is closed.", "unsure_response": null }, { "question_text": "How long must Advanced Compliance Technology, Inc. keep review reports and remediation records?", "options": [ "At least five years", "At least two years", "At least three years", "Until the next independent review is completed" ], "correct_answer": "At least five years", "correct_response": "Correct. Review reports, supporting records, and remediation logs must be kept for at least five years. Examiners can ask for past cycles at any time.", "incorrect_response": "Review reports and remediation records must be kept for at least five years. Examiners may ask for past review cycles at any time, so records from prior cycles must remain available.", "unsure_response": null } ], "enrichment_content": "

Key point: The independent reviewer sends the report directly to senior management — not to the BSA/AML Compliance Officer — because the review is a check on the compliance program itself.

" }