{
  "question_text": "During a compliance-driven closure review, you confirm that the customer's account is subject to an OFAC blocking order. Which set of actions is required?",
  "options": [
    "Halt standard closure, hold blocked funds in a segregated interest-bearing account, file a blocking report with OFAC within 10 business days, and keep the account open until OFAC authorizes disposition in writing",
    "Proceed with standard closure and submit a blocking report to OFAC within 30 calendar days of closing",
    "Close the account immediately, transfer funds to a federal escrow account, and notify OFAC within 10 business days",
    "Suspend the account, request customer instructions for fund disposition, and file a blocking report after funds are returned"
  ],
  "correct_answer": "Halt standard closure, hold blocked funds in a segregated interest-bearing account, file a blocking report with OFAC within 10 business days, and keep the account open until OFAC authorizes disposition in writing",
  "correct_response": "Correct. Standard closure procedures do not apply to blocked accounts. The account remains open and restricted, funds are segregated in an interest-bearing account, and the blocking report must be filed within 10 business days. Written OFAC authorization is required before any disposition occurs.",
  "incorrect_response": "A blocked account cannot be closed through standard procedures. The account must remain open and restricted. Blocked funds go into 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 for disposition — no action may be taken before that authorization arrives.",
  "unsure_response": null,
  "question_bank": [
    {
      "question_text": "A compliance team member identifies suspicious activity at the same time a closure decision is reached. According to the SAR-priority rule, what is the correct next step?",
      "options": [
        "File the SAR on FinCEN Form 111 and record the filing reference before taking any closure action",
        "Initiate the closure first, then file the SAR within 10 business days to maintain the timeline",
        "File the SAR and begin the closure simultaneously to avoid processing delays",
        "Defer the SAR until after the closure is complete to avoid alerting the customer"
      ],
      "correct_answer": "File the SAR on FinCEN Form 111 and record the filing reference before taking any closure action",
      "correct_response": "Correct. The SAR must be filed first, and the filing reference must be recorded in the case file before any closure step begins.",
      "incorrect_response": "When suspicious activity is involved, the SAR is filed on FinCEN Form 111 and the filing reference is recorded in the case file before any closure action begins. No closure step may proceed until this is complete.",
      "unsure_response": null
    },
    {
      "question_text": "A 314(a) check during closure review returns a match for the customer. What is the required response?",
      "options": [
        "Pause the closure immediately and follow Section 18 before proceeding",
        "Proceed with the closure and notify FinCEN of the match within 10 business days",
        "Complete the closure and document the 314(a) match in the case file",
        "File a SAR and continue the closure using expedited business-decision procedures"
      ],
      "correct_answer": "Pause the closure immediately and follow Section 18 before proceeding",
      "correct_response": "Correct. A 314(a) match requires an immediate pause of the closure. Section 18 procedures apply before any further action is taken.",
      "incorrect_response": "If a 314(a) check returns a match, the closure must be paused immediately and Section 18 procedures must be followed before any further closure action is taken. Continuing the closure would disrupt an active law enforcement information request.",
      "unsure_response": null
    }
  ],
  "enrichment_content": "<p><strong>OFAC blocking orders:</strong> Standard closure procedures do not apply to blocked accounts. Blocked funds must be held in a segregated, interest-bearing account. A blocking report is filed with OFAC within 10 business days of the blocking action. The account remains open and restricted until OFAC provides written authorization for disposition.</p><p><strong>SAR priority:</strong> If suspicious activity is involved, the SAR is filed on FinCEN Form 111 and the filing reference is recorded before any closure step begins.</p><p><strong>314(a) match:</strong> A match on an active FinCEN 314(a) search requires an immediate pause of the closure pending Section 18 procedures.</p>"
}