{
  "question_text": "An OFAC check during the closure procedure reveals that the customer's account is subject to a blocking order. Which action is required?",
  "options": [
    "Keep the account open and restricted; do not process standard closure until OFAC provides written authorization",
    "Close the account and file a blocking report with OFAC within 10 business days of closure",
    "Transfer the funds to the customer and document the disposition in the case file",
    "Process standard closure and move the funds to a segregated account while awaiting OFAC review"
  ],
  "correct_answer": "Keep the account open and restricted; do not process standard closure until OFAC provides written authorization",
  "correct_response": "Correct. A blocking order suspends standard closure. The account stays open and restricted, the blocked funds move to a segregated interest-bearing account, and a blocking report is filed within 10 business days. Closure cannot happen until OFAC authorizes it in writing.",
  "incorrect_response": "When an OFAC blocking order applies, standard closure procedures stop entirely. The account remains open and restricted. Blocked funds are moved to a segregated, interest-bearing account. A blocking report is filed with OFAC within 10 business days of the blocking action. The account stays open until OFAC provides written authorization — not just confirmation of the blocking, but authorization to dispose of the funds.",
  "unsure_response": null,
  "question_bank": [
    {
      "question_text": "What is the first required step in the closure procedure when suspicious activity is involved?",
      "options": [
        "File the SAR on FinCEN Form 111 and record the filing reference in the case file",
        "Draft the closure communication and review it for prohibited content",
        "Confirm that no active 314(a) search covers the customer",
        "Secure all transaction records and account files for the required retention period"
      ],
      "correct_answer": "File the SAR on FinCEN Form 111 and record the filing reference in the case file",
      "correct_response": "Correct. When suspicious activity is involved, filing the SAR and recording the filing reference is the first step. No other closure action proceeds until this is done.",
      "incorrect_response": "When suspicious activity is involved, the SAR must be filed on FinCEN Form 111 and the filing reference must be recorded in the case file before any other closure step begins. The 314(a) check, records review, and communication review all come after.",
      "unsure_response": null
    },
    {
      "question_text": "Before sending a compliance-driven closure communication to the customer, which of the following must be removed if present?",
      "options": [
        "Any reference to a SAR, suspicious activity, or a law enforcement inquiry",
        "The effective closure date and fund return instructions",
        "The customer's name and account identifying information",
        "Any statement that the relationship is being ended for business reasons"
      ],
      "correct_answer": "Any reference to a SAR, suspicious activity, or a law enforcement inquiry",
      "correct_response": "Correct. Before delivery, closure communications must be reviewed and stripped of any reference to a SAR, suspicious activity, or law enforcement. The only permissible explanation is that Rapido Facil Exchange Co. has made a business decision to end the relationship.",
      "incorrect_response": "Closure communications must be reviewed before delivery. Any reference to a SAR, suspicious activity, law enforcement inquiries, or the compliance nature of the decision must be removed. Disclosing this information is unlawful tipping off and carries federal criminal liability.",
      "unsure_response": null
    }
  ],
  "enrichment_content": "<p><strong>OFAC blocking orders:</strong> If an account is blocked, standard closure stops. The account stays open and restricted. Blocked funds go into a segregated, interest-bearing account. A blocking report is filed with OFAC within 10 business days. The account cannot be closed until OFAC provides written authorization for disposition.</p><p><strong>Tipping off:</strong> Closure communications must be reviewed before delivery. Remove any reference to a SAR, suspicious activity, or law enforcement. The only permissible language is that Rapido Facil Exchange Co. has made a business decision to end the relationship. Disclosing more than that is a federal crime.</p>"
}