Question

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

A broker-dealer compliance officer is updating the firm's written supervisory procedures regarding Currency Transaction Report (CTR) compliance under Bank Secrecy Act and FinCEN regulations. Which of the following requirements correctly apply to CTR filings? Select all that apply.

  1. They must be filed for physical currency transactions exceeding $10,000 executed in a single business day.Answer
  2. The member firm must submit the completed filing to FinCEN within 15 calendar days of the transaction.Answer
  3. C
    They must be filed for any suspicious wire transfer or check deposit exceeding $5,000.
  4. D
    The report must be filed within 30 calendar days of initial discovery of suspicious account activity.

Answer

Currency Transaction Reports (CTRs) must be filed for physical cash transactions exceeding $10,000 in a single business day, and the filing must be completed within 15 calendar days of the transaction.
The correct requirements dictate that Currency Transaction Reports (CTRs) are triggered by physical cash transactions exceeding $10,000 conducted in a single business day, and member firms must file the completed report with FinCEN within 15 calendar days.

Step-by-Step Solution

1
Identify the mandatory monetary threshold for Currency Transaction Reports (CTRs).
CTRs apply specifically to physical currency deposits, withdrawals, or exchanges exceeding $10,000 in a single business day.
FinCEN regulations set the CTR threshold at cash transactions over $10,000.
2
Determine the required filing timeframe for CTRs.
The broker-dealer has 15 calendar days from the date of the cash transaction to file the report with FinCEN.
The standard regulatory deadline for submitting a CTR is 15 calendar days.
3
Distinguish CTR rules from Suspicious Activity Report (SAR) rules.
Statements involving a $5,000 threshold and a 30-day timeline apply to SARs, not CTRs.
SARs govern suspicious activity of $5,000 or more with a 30-day filing window.

Key Concept

Currency Transaction Report (CTR) Rules and Thresholds
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