{
  "question_text": "When documenting a 314(a) search in the compliance file, which of the following must be recorded regardless of the search outcome?",
  "options": [
    "The search date, scope of records searched, names of all personnel who conducted the search, and both positive and negative results",
    "Only positive match results, since a negative result confirms no further action is needed",
    "The names of subjects searched and the date the positive match response was submitted to FinCEN",
    "A summary of customer transaction activity within the date range specified by the request"
  ],
  "correct_answer": "The search date, scope of records searched, names of all personnel who conducted the search, and both positive and negative results",
  "correct_response": "Correct. Complete documentation is required for every search — including negative results. This record demonstrates that the search was properly conducted and supports examination readiness.",
  "incorrect_response": "Every 314(a) search must be documented in full: the date, the scope of records searched, the names of personnel involved, and the outcome — whether a match was found or not. Negative results must be recorded just as positive ones are.",
  "unsure_response": null,
  "question_bank": [
    {
      "question_text": "A 314(a) search confirms a positive match. What two actions must follow?",
      "options": [
        "Submit a positive match response to FinCEN within the required timeframe, and file a SAR separately if the facts independently require one",
        "Submit a positive match response to FinCEN, which satisfies any concurrent SAR obligation",
        "Notify the customer of the match and submit a joint report to FinCEN",
        "Place the account on hold and await further instructions from FinCEN before filing any report"
      ],
      "correct_answer": "Submit a positive match response to FinCEN within the required timeframe, and file a SAR separately if the facts independently require one",
      "correct_response": "Correct. A positive match response and a SAR are independent obligations. The match response does not discharge a SAR requirement that arises from the same underlying facts.",
      "incorrect_response": "When a match is found, you must submit a positive match response to FinCEN on time. You must also separately evaluate whether the facts require a SAR — the match response does not replace that obligation.",
      "unsure_response": null
    },
    {
      "question_text": "Under a 314(a) request, which records must be searched?",
      "options": [
        "All customer records, transaction records, and account files, applying the date range specified in the request",
        "Only active customer accounts opened within the last 12 months",
        "Transaction records only, since customer records are protected by privacy law",
        "Records for customers whose names phonetically resemble a subject on the list"
      ],
      "correct_answer": "All customer records, transaction records, and account files, applying the date range specified in the request",
      "correct_response": "Correct. A complete search of all customer records, transaction records, and account files is required. The date range specified in the request must be applied. A missed match is a compliance failure.",
      "incorrect_response": "The search must cover all customer records, transaction records, and account files — not just a subset. The date range in the request defines the scope. Partial searches increase the risk of an undetected positive match.",
      "unsure_response": null
    }
  ],
  "enrichment_content": "<p><strong>Key point:</strong> Every 314(a) search must be fully documented — including negative results — and a positive match response does <strong>not</strong> replace a SAR obligation.</p><ul><li>Record the search date, scope of records searched, names of personnel, and all results.</li><li>Search all customer records, transaction records, and account files within the specified date range.</li><li>If the facts independently require a SAR, file it separately from the match response.</li></ul>"
}