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Question

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

On a single business day, a client deposits 9,500inphysicalpapercurrencyatonebranchofamemberbroker−dealerandlaterdeposits9,500 in physical paper currency at one branch of a member broker-dealer and later deposits 1,500 in physical paper currency at a different branch of the same firm. During the second transaction, the client asks the representative if the deposit will trigger government tax reporting. Under federal Bank Secrecy Act and FINRA anti-money laundering regulations, which of the following requirements correctly describes the firm's mandatory filing obligations?

  1. The firm must file a Currency Transaction Report (CTR) within 15 calendar days due to aggregated cash deposits exceeding $10,000, and must also file a Suspicious Activity Report (SAR) within 30 calendar days due to potential structuring.Answer
  2. B
    The firm is required to file only a Suspicious Activity Report (SAR) within 30 calendar days, because neither individual cash transaction exceeded the $10,000 reporting limit.
  3. C
    The firm is required to file only a Currency Transaction Report (CTR) within 30 calendar days, as CTR filings eliminate the need for a Suspicious Activity Report when currency is involved.
  4. D
    The firm must file a joint CTR/SAR submission directly to the Securities and Exchange Commission (SEC) within 15 calendar days of the second deposit.

Answer

The broker-dealer must file a Currency Transaction Report (CTR) with FinCEN within 15 calendar days because the client's aggregate cash deposits in a single business day (11,000)exceededthe11,000) exceeded the 10,000 threshold. In addition, because the client engaged in potential structuring (splitting transactions to avoid reporting limits), the firm must file a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days.
Under the Bank Secrecy Act (BSA), broker-dealers must aggregate all cash deposits made by a single customer across all branches within a single business day. Because the client deposited 9,500and9,500 and 1,500, the total physical currency received was 11,000,whichexceedsthe11,000, which exceeds the 10,000 CTR threshold and mandates a Currency Transaction Report (CTR) filing within 15 calendar days. Additionally, because the client attempted to structure the cash deposits to evade reporting rules and questioned the representative regarding threshold triggers, the conduct constitutes suspicious activity exceeding the $5,000 threshold. Therefore, the firm must also file a Suspicious Activity Report (SAR) within 30 calendar days.

Step-by-Step Solution

1
Aggregate physical currency deposits conducted by the customer on the same business day across all firm locations.
9,500+9,500 + 1,500 = $11,000 in physical cash.
Broker-dealers are required to aggregate multiple cash transactions conducted on the same business day to determine if the $10,000 threshold is breached.
2
Evaluate Currency Transaction Report (CTR) requirements based on the aggregated cash amount.
CTR mandatory within 15 calendar days of the transaction.
The Bank Secrecy Act mandates filing a CTR for physical currency deposits exceeding $10,000 in a single business day within 15 calendar days.
3
Evaluate Suspicious Activity Report (SAR) requirements based on customer conduct and amount.
SAR mandatory within 30 calendar days.
Attempting to structure deposits into smaller amounts to avoid threshold detection involves suspicious activity exceeding $5,000, requiring a SAR filing within 30 calendar days.

Key Concept

Dual AML Reporting Obligations (CTR vs. SAR thresholds and timelines)
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Topics

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