A compliance officer at a broker-dealer is reviewing written supervisory procedures regarding Customer Identification Programs (CIP), Anti-Money Laundering (AML) reporting, and Office of Foreign Assets Control (OFAC) sanctions compliance. Which of the following statements accurately describe mandatory broker-dealer compliance obligations under federal regulations? Select all that apply.
- Verifying the customer's identity through reliable documentary or non-documentary methods within a reasonable time after account opening under the Customer Identification Program (CIP).Answer
- Screening prospective and existing customer accounts against the Specially Designated Nationals (SDN) list maintained by the Office of Foreign Assets Control (OFAC).Answer
- CFiling a Currency Transaction Report (CTR) with FinCEN within 30 calendar days whenever a customer conducts a wire transfer of $5,000 or more in a single business day.
- DNotifying the account holder in writing within 15 calendar days following the submission of a Suspicious Activity Report (SAR) to FinCEN.
Answer
The statements requiring verification of customer identity within a reasonable timeframe under CIP and screening customer names against the OFAC Specially Designated Nationals list are both correct regulatory obligations.
Verifying customer identities under CIP procedures within a reasonable timeframe and checking account names against the OFAC SDN list to prevent illegal sanctions violations are core mandatory anti-money laundering and sanctions compliance duties for broker-dealers.
Step-by-Step Solution
Key Concept
AML, CIP, and OFAC Sanctions Obligations