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Certified Bank Secrecy Act Officer (CBSAO) certification
Exam Questions and Correct Answers with
EXPLANATIONS LATEST THIS YEAR
Summarized Exam Coverage
The Certified Bank Secrecy Act Officer (CBSAO) certification is a professional credential offered by
the Institute of Certified Bankers (ICB) , a subsidiary of the American Bankers Association (ABA). The
exam is designed for professionals responsible for developing, implementing, and administering a
financial institution's Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance program.
The CBSAO exam covers comprehensive BSA/AML requirements, including:
• BSA/AML Compliance Program: The "Five Pillars" of an effective program
• Reporting Requirements: Currency Transaction Reports (CTRs), Suspicious Activity Reports
(SARs), and Monetary Instrument Logs
• Customer Due Diligence (CDD) : Customer Identification Program (CIP), Beneficial Ownership
requirements, and Enhanced Due Diligence (EDD)
• OFAC Compliance: Sanctions screening and reporting requirements
• Risk Assessment: Identifying and mitigating BSA/AML risks across products, services, customers,
and geographies
• Recordkeeping and Information Sharing: FinCEN Section 314(a) requests, information sharing
protocols
• Examination and Enforcement: Regulatory expectations, examiner guidance, and consequences
for non-compliance
The exam is administered in a proctored format with a focus on both regulatory knowledge and practical
application through scenario-based questions. Candidates must complete the full curriculum and pass
the certification exam with a score of 80% or higher. Topics incorporate recent regulatory updates
including the Corporate Transparency Act (beneficial ownership), elder financial exploitation reporting,
and emerging risk areas such as cryptocurrency and human trafficking.
1. Under the Bank Secrecy Act (BSA) as originally enacted, what was the primary purpose of requiring
financial institutions to keep records and file reports?
A) To assist law enforcement in detecting and preventing money laundering
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B) To simplify tax collection for the IRS
C) To reduce paperwork burdens on banks
D) To protect customer privacy
Answer: A
The BSA's original purpose was to create a paper trail of large currency transactions to help law
enforcement investigate financial crimes, including tax evasion and money laundering, by requiring
financial institutions to keep records and file reports.
2. Which statement best describes the Board of Directors' ultimate responsibility regarding BSA/AML
compliance?
A) The Board is not responsible for BSA compliance
B) The Board is ultimately responsible for BSA/AML compliance
C) Only the BSA Officer is responsible
D) Responsibility is shared equally among all employees
Answer: B
Although the BSA Officer coordinates daily compliance, the Board of Directors holds ultimate
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responsibility for ensuring the institution has an effective BSA/AML compliance program and receives
appropriate training.
3. FinCEN section 314(a) requests relate to what type of information sharing?
A) Requests for customer identification information
B) Requests for currency transaction reports
C) Law enforcement requests for account information during money laundering or terrorism
investigations
D) Requests for exemption approvals
Answer: C
Section 314(a) authorizes federal, state, local, or foreign law enforcement agencies investigating
terrorism or money laundering to request that FinCEN solicit specific account information from financial
institutions on their behalf.
4. An external audit of your bank's BSA program identified multiple deficiencies. According to regulatory
guidance, how often should independent testing of the BSA program be conducted?
A) Annually only
B) Every 12 to 18 months, depending on risk profile
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C) Every 2 years for low-risk institutions
D) Only when required by examiners
Answer: B
*Regulators recommend independent testing every 12 to 18 months, with the frequency based on the
institution's risk profile; higher-risk institutions may require more frequent testing.*
5. A customer makes a cash deposit of $9,000 in the morning and later that day withdraws $3,000 in
cash from an ATM. Is a Currency Transaction Report (CTR) required?
A) Yes, because total cash activity exceeded $10,000
B) No, because the withdrawal was from an ATM
C) No, because the transactions were separate and none individually exceeded $10,000
D) Yes, because the ATM withdrawal is considered cash out
Answer: C
A CTR is required when a single transaction or multiple transactions by or on behalf of any person exceed
$10,000 in cash during a single business day. Neither transaction individually met the threshold.
6. Which of the following would NOT be considered an eligible exemption for CTR filing purposes under
the BSA's exemption rules?
Certified Bank Secrecy Act Officer (CBSAO) certification
Exam Questions and Correct Answers with
EXPLANATIONS LATEST THIS YEAR
Summarized Exam Coverage
The Certified Bank Secrecy Act Officer (CBSAO) certification is a professional credential offered by
the Institute of Certified Bankers (ICB) , a subsidiary of the American Bankers Association (ABA). The
exam is designed for professionals responsible for developing, implementing, and administering a
financial institution's Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance program.
The CBSAO exam covers comprehensive BSA/AML requirements, including:
• BSA/AML Compliance Program: The "Five Pillars" of an effective program
• Reporting Requirements: Currency Transaction Reports (CTRs), Suspicious Activity Reports
(SARs), and Monetary Instrument Logs
• Customer Due Diligence (CDD) : Customer Identification Program (CIP), Beneficial Ownership
requirements, and Enhanced Due Diligence (EDD)
• OFAC Compliance: Sanctions screening and reporting requirements
• Risk Assessment: Identifying and mitigating BSA/AML risks across products, services, customers,
and geographies
• Recordkeeping and Information Sharing: FinCEN Section 314(a) requests, information sharing
protocols
• Examination and Enforcement: Regulatory expectations, examiner guidance, and consequences
for non-compliance
The exam is administered in a proctored format with a focus on both regulatory knowledge and practical
application through scenario-based questions. Candidates must complete the full curriculum and pass
the certification exam with a score of 80% or higher. Topics incorporate recent regulatory updates
including the Corporate Transparency Act (beneficial ownership), elder financial exploitation reporting,
and emerging risk areas such as cryptocurrency and human trafficking.
1. Under the Bank Secrecy Act (BSA) as originally enacted, what was the primary purpose of requiring
financial institutions to keep records and file reports?
A) To assist law enforcement in detecting and preventing money laundering
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B) To simplify tax collection for the IRS
C) To reduce paperwork burdens on banks
D) To protect customer privacy
Answer: A
The BSA's original purpose was to create a paper trail of large currency transactions to help law
enforcement investigate financial crimes, including tax evasion and money laundering, by requiring
financial institutions to keep records and file reports.
2. Which statement best describes the Board of Directors' ultimate responsibility regarding BSA/AML
compliance?
A) The Board is not responsible for BSA compliance
B) The Board is ultimately responsible for BSA/AML compliance
C) Only the BSA Officer is responsible
D) Responsibility is shared equally among all employees
Answer: B
Although the BSA Officer coordinates daily compliance, the Board of Directors holds ultimate
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responsibility for ensuring the institution has an effective BSA/AML compliance program and receives
appropriate training.
3. FinCEN section 314(a) requests relate to what type of information sharing?
A) Requests for customer identification information
B) Requests for currency transaction reports
C) Law enforcement requests for account information during money laundering or terrorism
investigations
D) Requests for exemption approvals
Answer: C
Section 314(a) authorizes federal, state, local, or foreign law enforcement agencies investigating
terrorism or money laundering to request that FinCEN solicit specific account information from financial
institutions on their behalf.
4. An external audit of your bank's BSA program identified multiple deficiencies. According to regulatory
guidance, how often should independent testing of the BSA program be conducted?
A) Annually only
B) Every 12 to 18 months, depending on risk profile
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C) Every 2 years for low-risk institutions
D) Only when required by examiners
Answer: B
*Regulators recommend independent testing every 12 to 18 months, with the frequency based on the
institution's risk profile; higher-risk institutions may require more frequent testing.*
5. A customer makes a cash deposit of $9,000 in the morning and later that day withdraws $3,000 in
cash from an ATM. Is a Currency Transaction Report (CTR) required?
A) Yes, because total cash activity exceeded $10,000
B) No, because the withdrawal was from an ATM
C) No, because the transactions were separate and none individually exceeded $10,000
D) Yes, because the ATM withdrawal is considered cash out
Answer: C
A CTR is required when a single transaction or multiple transactions by or on behalf of any person exceed
$10,000 in cash during a single business day. Neither transaction individually met the threshold.
6. Which of the following would NOT be considered an eligible exemption for CTR filing purposes under
the BSA's exemption rules?
