{
  "question_text": "How often does Rapido Facil Exchange Co. check OFAC rulemaking and the SDN sanctions list?",
  "options": [
    "Every day",
    "Every week",
    "Every month",
    "Every three months"
  ],
  "correct_answer": "Every day",
  "correct_response": "Correct. OFAC sources are checked every day. Sanctions list changes can happen at any time, so daily monitoring is required to catch them quickly.",
  "incorrect_response": "OFAC sources must be checked every day — not weekly or monthly. Sanctions list changes can go into effect at any time, so waiting longer than a day creates a gap between when the change happens and when Rapido Facil Exchange Co. knows about it.",
  "unsure_response": null,
  "question_bank": [
    {
      "question_text": "When must staff complete required compliance training after a regulatory change affects Rapido Facil Exchange Co.'s procedures?",
      "options": [
        "Before the date the new rule takes effect",
        "Within 60 days of the Board's written notification",
        "After the Compliance Committee approves the updated program",
        "Within 30 days of the Compliance Committee's approval"
      ],
      "correct_answer": "Before the date the new rule takes effect",
      "correct_response": "Correct. When procedures change, any required training must be completed before the new rule takes effect. Training after the effective date means staff may have already processed transactions the wrong way.",
      "incorrect_response": "Required training must be completed before the effective date — the date the new rule takes effect. Completing it after means staff could be working under outdated procedures after the rule is already in force. The goal is to make sure everyone is ready before the change happens.",
      "unsure_response": null
    },
    {
      "question_text": "A new rule requires Rapido Facil Exchange Co. to add new steps to its procedures. What makes this a material change?",
      "options": [
        "It requires new steps or procedures",
        "It was issued by a federal agency",
        "It applies to a state where Rapido Facil Exchange Co. is licensed",
        "It was found during the weekly monitoring review"
      ],
      "correct_answer": "It requires new steps or procedures",
      "correct_response": "Correct. One of the four criteria for a material change is that it requires new procedures. That criterion is met here, which means the full amendment process applies.",
      "incorrect_response": "A change is material if it changes a dollar threshold, requires new steps, affects what you tell customers, or changes a filing requirement. Requiring new procedures meets one of those criteria. Where the rule came from or how it was found does not determine materiality.",
      "unsure_response": null
    }
  ],
  "enrichment_content": "<p><strong>Key Points on Monitoring and Training:</strong></p><ul><li>Rapido Facil Exchange Co. checks <strong>OFAC</strong> every <strong>day</strong> — sanctions changes can happen at any time.</li><li><strong>FinCEN</strong> rules and guidance are checked every <strong>week</strong>.</li><li>State rules and FinCEN enforcement actions are checked every <strong>month</strong>.</li></ul><p>When a rule change requires new procedures, any required training must be completed <strong>before</strong> the new rule takes effect — not after. A change is material if it changes a dollar amount, requires new steps, affects what you tell customers, or changes a filing requirement.</p>"
}