{
  "question_text": "After submitting a positive match response to FinCEN, what must you check as a separate and independent step?",
  "options": [
    "Whether the facts independently require a SAR to be filed",
    "Whether the subject's account should be closed immediately",
    "Whether FinCEN has confirmed receipt of the positive match response",
    "Whether the response window must be extended for additional verification"
  ],
  "correct_answer": "Whether the facts independently require a SAR to be filed",
  "correct_response": "Correct. A 314(a) match response does not replace a SAR. After submitting the match response, you must separately evaluate whether the underlying facts require a SAR filing.",
  "incorrect_response": "A 314(a) match response and a SAR are separate obligations. Submitting the match response does not satisfy any SAR requirement that arises independently from the same facts — you must check this separately.",
  "unsure_response": null,
  "question_bank": [
    {
      "question_text": "When documenting a 314(a) search, which of the following must be included in the compliance file?",
      "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 and the date the match response was submitted to FinCEN",
        "The names of subjects on the list and a copy of the FinCEN request",
        "A list of all customer accounts reviewed, regardless of whether a match was found"
      ],
      "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. The compliance file must include all four elements for every search — including searches that found no matches.",
      "incorrect_response": "Complete documentation means recording the search date, the scope of records reviewed, who conducted the search, and the outcome — positive or negative. Negative results must be documented too.",
      "unsure_response": null
    },
    {
      "question_text": "How are subjects matched during a 314(a) search?",
      "options": [
        "By name, address, and identification number, within the date range specified in the request",
        "By name only — address and identification number are used only if the name produces multiple results",
        "By identification number only, since names and addresses may change",
        "By any two of three identifiers: name, address, or identification number"
      ],
      "correct_answer": "By name, address, and identification number, within the date range specified in the request",
      "correct_response": "Correct. Each subject must be matched using all three identifiers — name, address, and identification number — and the search must be confined to the date range specified in the request.",
      "incorrect_response": "Matching requires all three identifiers: name, address, and identification number. The search must also be limited to the date range specified in the request. Using fewer identifiers increases the risk of a missed or incorrect match.",
      "unsure_response": null
    }
  ],
  "enrichment_content": "<p><strong>Key point:</strong> A 314(a) match response does <strong>not</strong> replace a SAR obligation. After submitting the match response, always check whether the facts separately require a SAR.</p><ul><li>Match each subject by name, address, and identification number within the specified date range.</li><li>Document every search — including negative results — in the compliance file.</li><li>The request and all related information are strictly confidential.</li></ul>"
}