{
  "question_text": "The independent reviewer delivers the written report to which party?",
  "options": [
    "Directly to senior management, not through the BSA/AML Compliance Officer",
    "To the BSA/AML Compliance Officer, who distributes it to senior management",
    "To both the BSA/AML Compliance Officer and senior management at the same time",
    "To the Florida licensing authority as part of the examination record"
  ],
  "correct_answer": "Directly to senior management, not through the BSA/AML Compliance Officer",
  "correct_response": "Correct. The reviewer delivers the report directly to senior management. Routing the report through the BSA/AML Compliance Officer would compromise the independence of the review.",
  "incorrect_response": "The independent reviewer delivers the written report directly to senior management — it does not route through the BSA/AML Compliance Officer. This direct reporting structure is a core independence requirement.",
  "unsure_response": null,
  "question_bank": [
    {
      "question_text": "What is the minimum retention period for the review report, supporting workpapers, and remediation records?",
      "options": [
        "Five years",
        "Three years",
        "Seven years",
        "Two years"
      ],
      "correct_answer": "Five years",
      "correct_response": "Correct. Review reports, workpapers, and remediation records must be retained for a minimum of five years. Examiners may request prior-cycle documentation during any examination.",
      "incorrect_response": "The minimum retention period for review reports, supporting workpapers, and remediation records is five years. Examiners may request prior-cycle documentation at any examination.",
      "unsure_response": null
    },
    {
      "question_text": "During the independent review, what access must the BSA/AML Compliance Officer provide to the reviewer?",
      "options": [
        "Full access to systems, records, and personnel",
        "Access to policies and procedures only, with personnel access restricted",
        "Read-only access to records, with no direct access to personnel",
        "Access limited to records from the current review cycle only"
      ],
      "correct_answer": "Full access to systems, records, and personnel",
      "correct_response": "Correct. The BSA/AML Compliance Officer must provide full access to systems, records, and personnel. Restricted access produces incomplete findings and weakens the program's defensibility.",
      "incorrect_response": "The BSA/AML Compliance Officer must provide full access to systems, records, and personnel during the review. Restricted access produces incomplete findings, which weakens the program's defensibility with examiners.",
      "unsure_response": null
    }
  ],
  "enrichment_content": "<p><strong>Key point:</strong> The independent reviewer delivers the written report directly to senior management — not through the BSA/AML Compliance Officer. This structure is required to maintain the independence of the review function.</p><p>During the review, the BSA/AML Compliance Officer must provide full access to systems, records, and personnel. Review records must be retained for a minimum of five years, and documentation must be kept examination-ready at all times.</p>"
}