{
  "question_text": "After submitting a positive match response to FinCEN under a 314(a) request, what additional compliance obligation may independently arise?",
  "options": [
    "A SAR must be filed separately if the underlying facts independently require one",
    "No further action is required once the positive match response has been submitted",
    "The compliance officer must notify the subject that they were identified in the search",
    "A second search must be conducted to confirm the match before any SAR is considered"
  ],
  "correct_answer": "A SAR must be filed separately if the underlying facts independently require one",
  "correct_response": "Correct. A 314(a) match response and a SAR are independent obligations. Submitting the match response to FinCEN does not discharge any separately arising SAR requirement.",
  "incorrect_response": "A 314(a) match response does not replace a SAR obligation. If the facts independently require a SAR, it must be filed separately — the two reports serve different purposes and neither substitutes for the other.",
  "unsure_response": null,
  "question_bank": [
    {
      "question_text": "Which of the following must be recorded in the compliance file following a 314(a) search, regardless of whether a match was found?",
      "options": [
        "The search date, scope of records searched, names of personnel who conducted the search, and both positive and negative results",
        "Only positive match results, since negative results indicate no compliance action was required",
        "The search date and the name of the subject identified, if any",
        "A summary of the transaction history for all customers searched"
      ],
      "correct_answer": "The search date, scope of records searched, names of personnel who conducted the search, and both positive and negative results",
      "correct_response": "Correct. Complete documentation of every search — including negative results — is required to demonstrate that the search was properly conducted and to support examination readiness.",
      "incorrect_response": "The compliance file must document the search date, scope, personnel involved, and both positive and negative results. Recording only matches creates a gap in the examination record.",
      "unsure_response": null
    },
    {
      "question_text": "Under a 314(a) request, the response window is typically measured from which point in time?",
      "options": [
        "The issuance date of the request",
        "The date the BSA/AML Compliance Officer first reviews the subject list",
        "The date the search is completed",
        "The date Rapido Facil Exchange Co. acknowledges receipt of the request to FinCEN"
      ],
      "correct_answer": "The issuance date of the request",
      "correct_response": "Correct. The two-week response window runs from the issuance date of the request, not from the date it is received or reviewed. Obtaining the subject list promptly preserves the full window.",
      "incorrect_response": "The response window is typically two weeks from the issuance date of the request. Delays in retrieving the subject list reduce the time available to complete the required search.",
      "unsure_response": null
    }
  ],
  "enrichment_content": "<p><strong>Key point:</strong> A 314(a) match response and a SAR are independent obligations — one does not replace the other. If the facts require a SAR, it must be filed separately regardless of whether a match response was already submitted to FinCEN.</p><ul><li>The response window is typically two weeks from the <strong>issuance date</strong> of the request.</li><li>Every search must be documented — including negative results — to support examination readiness.</li><li>The request, subject identities, and all results are strictly confidential.</li></ul>"
}