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

A customer visits a broker-dealer's branch office and deposits 7,200inphysicalcashintotheirbrokerageaccount.Thefollowingmorning,thesamecustomerreturnstodepositanadditional7,200 in physical cash into their brokerage account. The following morning, the same customer returns to deposit an additional 4,300 in physical currency and requests that the representative record the deposits separately to ensure federal reporting requirements are avoided. Which of the following statements correctly describes the firm's regulatory filing obligations?

  1. The firm must file a Currency Transaction Report (CTR) within 15 calendar days because cash deposits exceeded $10,000, and a Suspicious Activity Report (SAR) within 30 calendar days due to structuring.Answer
  2. B
    The firm must file only a Suspicious Activity Report (SAR) within 15 calendar days, as evidence of structuring waives the standard Currency Transaction Report threshold.
  3. C
    The firm must file only a Currency Transaction Report (CTR) within 30 calendar days, as CTR filings automatically notify FinCEN of suspicious transaction patterns.
  4. D
    The firm is required to file a Suspicious Activity Report (SAR) within 30 calendar days, but no Currency Transaction Report (CTR) is needed because neither individual deposit exceeded $10,000.

Answer

The firm must file a Currency Transaction Report (CTR) within 15 calendar days because physical currency deposits exceeded $10,000, and file a Suspicious Activity Report (SAR) within 30 calendar days due to structuring.
The correct answer accounts for both FinCEN reporting mandates triggered by the scenario. Under the Bank Secrecy Act, broker-dealers must file a Currency Transaction Report (CTR) for physical cash transactions exceeding 10,000inasingledayorrelatedtransactionswithin15calendardaysoftheevent.Simultaneously,attemptstoevadereportinglimits(structuring)involvingatleast10,000 in a single day or related transactions within 15 calendar days of the event. Simultaneously, attempts to evade reporting limits (structuring) involving at least 5,000 mandate the filing of a Suspicious Activity Report (SAR) within 30 calendar days. Neither report satisfies the requirement of the other.

Step-by-Step Solution

1
Calculate the total physical currency deposited to determine CTR applicability.
7,200+7,200 + 4,300 = $11,500 in total physical currency.
Broker-dealers must aggregate physical currency transactions executed by or on behalf of the same person within a single business day or short related period. Because 11,500exceedsthe11,500 exceeds the 10,000 threshold, a Currency Transaction Report (CTR) must be filed with FinCEN within 15 calendar days.
2
Evaluate the customer's behavior for suspicious activity and SAR reporting obligations.
The customer's request to separate transactions to avoid reporting limits constitutes illegal structuring.
Any transaction or series of transactions involving $5,000 or more that appears designed to evade Bank Secrecy Act requirements requires the filing of a Suspicious Activity Report (SAR) within 30 calendar days.
3
Determine the combined regulatory compliance requirements.
Both a CTR (15 days) and a SAR (30 days) must be filed independently.
CTR and SAR requirements are separate mandates; fulfilling one does not exempt the firm from fulfilling the other.

Key Concept

Anti-Money Laundering (AML) Reporting Thresholds and Timelines (CTR vs. SAR)
Estimated Time:1m 15s
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Topics

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