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

A broker-dealer's anti-money laundering compliance department identifies a pattern where an individual makes three separate cash deposits of $3,500 into a brokerage account across three consecutive business days, followed by an immediate request to transfer the funds abroad. The firm determines the activity constitutes structured transactions designed to evade cash reporting. Under Bank Secrecy Act (BSA) rules, which reporting action is the firm required to take?

  1. File a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days of initial detection.Answer
  2. B
    File a Currency Transaction Report (CTR) with FinCEN within 15 calendar days because the aggregated cash total exceeds $10,000.
  3. C
    File a Suspicious Activity Report (SAR) with FinCEN within 15 calendar days and notify the client of the filing.
  4. D
    File both a Currency Transaction Report (CTR) and a Suspicious Activity Report (SAR) within 30 calendar days.

Answer

The broker-dealer must file a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days of initial detection of the structured activity.
Under Bank Secrecy Act (BSA) and FINRA regulations, broker-dealers are required to file a Suspicious Activity Report (SAR) for any transaction or pattern of transactions involving $5,000 or more that is suspected of involving illegal activity or structuring to evade CTR requirements. The deadline for filing a SAR is 30 calendar days from the date of initial detection by the firm. Furthermore, the firm must maintain strict confidentiality and must never inform the client that a SAR has been filed.

Step-by-Step Solution

1
Evaluate Currency Transaction Report (CTR) applicability
No CTR filing is required because cash deposits did not exceed $10,000 in a single business day.
CTR obligations under FinCEN rules strictly apply to physical cash transactions exceeding $10,000 within one business day for a single customer.
2
Evaluate Suspicious Activity Report (SAR) applicability
SAR filing is mandatory because the transaction total exceeds $5,000 and involves suspicious structuring behavior.
Broker-dealers must report any transaction or series of transactions involving $5,000 or more when the firm suspects money laundering, structuring, or lack of business purpose.
3
Determine the mandatory regulatory timeline and confidentiality rules
The SAR must be submitted within 30 calendar days of detection without disclosing the filing to the customer.
Federal anti-money laundering regulations mandate a 30-day reporting window for SARs and prohibit disclosure to the customer.

Key Concept

Anti-Money Laundering (AML) Reporting Thresholds and Deadlines (SAR vs. CTR)
Estimated Time:1m 30s
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Topics

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