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Question

Difficulty: MediumAnti-Money Laundering (AML), KYC, and Sanctions Compliance

A registered representative observes a series of foreign wire transfers totaling $7,500 into a customer's brokerage account over two days. The transactions appear to have no logical commercial rationale and seem structured to layer funds. Under FinCEN regulations for broker-dealers, what dollar threshold triggers the mandatory filing of a Suspicious Activity Report (SAR), and what is the standard filing deadline following initial detection?

  1. A threshold of $5,000 or more, with a filing deadline within 30 calendar days of detectionAnswer
  2. B
    A threshold of currency exceeding $10,000, with a filing deadline within 15 calendar days of detection
  3. C
    A threshold of currency exceeding $10,000, with a filing deadline within 30 calendar days of detection
  4. D
    A threshold of $5,000 or more, with a filing deadline within 15 calendar days of detection

Answer

A threshold of $5,000 or more, with a filing deadline within 30 calendar days of detection
Under Bank Secrecy Act (BSA) rules enforced by FinCEN and FINRA, broker-dealers must file a Suspicious Activity Report (SAR) for any transaction involving or aggregating to $5,000 or more if the firm suspects money laundering, structuring, or a lack of legitimate business purpose. The firm must submit the SAR within 30 calendar days of becoming aware of the suspicious activity.

Step-by-Step Solution

1
Identify the type of report required based on transaction characteristics.
The activity involves potential money laundering/layering via wire transfers without business purpose, requiring a Suspicious Activity Report (SAR).
Non-cash suspicious activity requires a SAR rather than a Currency Transaction Report (CTR).
2
Determine the monetary threshold for broker-dealer SAR filings under FinCEN and FINRA rules.
The threshold is $5,000 or more in funds or assets.
Broker-dealers are obligated to report suspicious activity once the transaction amount reaches or exceeds $5,000.
3
Determine the required filing timeframe for submitting the SAR to FinCEN.
The filing must occur within 30 calendar days from the initial date of detection.
Federal anti-money laundering regulations mandate a 30-calendar-day window following detection of a suspicious pattern.

Key Concept

FinCEN SAR Reporting Thresholds and Timelines for Broker-Dealers
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Topics

Anti-Money Laundering (AML), KYC, and Sanctions Compliance