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Question

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

A compliance officer at a member broker-dealer reviews an account where a customer conducted cash deposits of 4,500,4,500, 4,800, and 4,700onthreeconsecutivebusinessdays(totaling4,700 on three consecutive business days (totaling 14,000), followed by an immediate request to wire the funds overseas. The compliance officer determines that this pattern represents structuring to evade currency reporting requirements. What is the firm's primary reporting obligation under Bank Secrecy Act (BSA) regulations?

  1. File a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days, while keeping the filing confidential from the customer.Answer
  2. B
    File a Currency Transaction Report (CTR) within 15 calendar days based on cumulative cash deposits exceeding $10,000 over the three-day period.
  3. C
    File a Currency Transaction Report (CTR) within 30 calendar days and notify the account owner in writing.
  4. D
    File a Suspicious Activity Report (SAR) only if an individual daily cash deposit exceeds $10,000.

Answer

The firm must file a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days of detection, while strictly maintaining confidentiality by not notifying the customer.
The correct response identifies that structuring cash transactions into amounts below 10,000acrossconsecutivedaystoevadeCTRreportingconstitutessuspiciousactivity.Becausethetotalaggregateinvolved(10,000 across consecutive days to evade CTR reporting constitutes suspicious activity. Because the total aggregate involved ( 14,000) exceeds the $5,000 SAR threshold, a Suspicious Activity Report (SAR) must be filed with FinCEN within 30 calendar days, and the representative/firm is legally prohibited from informing the client.

Step-by-Step Solution

1
Analyze the daily transaction amounts and transaction types.
Each individual daily deposit (4,500,4,500, 4,800, and 4,700)isunderthe4,700) is under the 10,000 single-business-day cash threshold required for a Currency Transaction Report (CTR).
CTRs are only triggered when currency deposits or withdrawals exceed $10,000 on a single business day.
2
Identify potential red flags and evaluate suspicious activity thresholds.
The total aggregate amount of 14,000acrossconsecutivedaysindicatesillegalstructuring,whichexceedsthe14,000 across consecutive days indicates illegal structuring, which exceeds the 5,000 SAR threshold.
Broker-dealers must file a SAR for suspicious transactions or structuring involving $5,000 or more.
3
Determine the regulatory filing timeframe and disclosure rules.
A SAR must be filed with FinCEN within 30 calendar days of initial detection, and disclosure of the filing to the client is illegal.
BSA rules mandate a 30-day SAR filing window and strict non-disclosure to protect law enforcement investigations.

Key Concept

Distinguishing between CTR (10,000+single−daycashthreshold/15days)andSAR(10,000+ single-day cash threshold / 15 days) and SAR ( 5,000+ suspicious/structured threshold / 30 days) requirements under BSA rules.
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Topics

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