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

During account onboarding for a new corporate entity, a broker-dealer's compliance department performs sanctions screening and identifies a confirmed hit matching the customer against the Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons (SDN) list. Which of the following procedures must the broker-dealer execute to remain compliant with federal law?

  1. Block the property and any property interests of the SDN and report the blocked assets to OFAC within 10 business days.Answer
  2. B
    File a Currency Transaction Report (CTR) with FinCEN within 15 calendar days of identifying the customer on the list.
  3. C
    Reject the account application and file a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days while allowing the client to transfer assets back to the originating institution.
  4. D
    Issue a written Customer Identification Program (CIP) notice to the customer requesting supplemental identification documentation within 30 calendar days.

Answer

The firm must block the property and property interests of the Specially Designated National (SDN) and file a report with OFAC within 10 business days.
Under regulations administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), broker-dealers are strictly prohibited from dealing with individuals or entities on the Specially Designated Nationals (SDN) list. Upon confirming a match, the firm must block (freeze) the assets immediately and file a blocked property report with OFAC within 10 business days.

Step-by-Step Solution

1
Identify the regulatory body and requirement governing Specially Designated Nationals (SDNs).
OFAC enforces U.S. economic and trade sanctions against targeted foreign countries, regimes, and named individuals/entities on the SDN list.
Matching a customer to the SDN list triggers OFAC sanctions enforcement regulations.
2
Determine the mandatory immediate action upon confirming an SDN match.
The firm must block (freeze) any accounts, property, or transactions associated with the designated entity or individual immediately.
Unblocking or releasing funds to an SDN constitutes a violation of federal sanctions laws.
3
Identify the mandatory reporting timeframe for OFAC blocked assets.
The firm must report blocked property to OFAC within 10 business days of taking the blocking action.
Federal OFAC reporting regulations specify a 10 business day deadline for reporting blocked or rejected transactions.

Key Concept

OFAC Sanctions Compliance and SDN Asset Blocking Requirements
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Topics

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