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

Match each federal Anti-Money Laundering (AML), Customer Due Diligence (CDD), or PATRIOT Act compliance mandate with its specific regulatory requirement or filing protocol.

  • USA PATRIOT Act Section 314(a) Information RequestMandatory bi-weekly record search for specified suspect subjects, requiring member firms to report matches back to FinCEN within 14 calendar days.
  • USA PATRIOT Act Section 314(b) Information SharingVoluntary information sharing among financial institutions regarding suspected money laundering or terrorist financing under statutory safe harbor protection.
  • FinCEN Customer Due Diligence (CDD) Beneficial Ownership RequirementMandatory identification and identity verification of equity owners of 25%25\% or more of a legal entity customer, plus one controlling manager.
  • FinCEN Form 105 (Report of International Transportation of Currency or Monetary Instruments - CMIR)Mandatory filing triggered whenever currency or physical monetary instruments exceeding $10,000\$10,000 are physically transported into or out of the United States.

Answer

USA PATRIOT Act Section 314(a) matches the 14-day FinCEN subject search protocol; Section 314(b) matches voluntary institution-to-institution information sharing under safe harbor; FinCEN CDD Rule matches the 25%25\% equity threshold for legal entity beneficial ownership; and CMIR (Form 105) matches the report for physically transporting over $10,000\$10,000 in cash/monetary instruments across U.S. borders.
Each match correctly aligns the specific AML mandate with its governing federal regulation: USA PATRIOT Act Section 314(a) requires searching firm records for FinCEN-identified suspects within 14 calendar days; Section 314(b) grants safe harbor for voluntary financial institution information sharing; FinCEN CDD rules require identifying beneficial owners holding at least 25%25\% equity in corporate accounts; and FinCEN Form 105 (CMIR) applies to physical cross-border transport of cash/monetary instruments over $10,000\$10,000.

Step-by-Step Solution

1
Analyze the USA PATRIOT Act Section 314(a) regulatory scope.
Identify that Section 314(a) governs law-enforcement-driven requests issued by FinCEN requiring firms to search account history and respond within 14 calendar days.
Section 314(a) establishes mandatory federal regulatory lookup requirements.
2
Analyze the USA PATRIOT Act Section 314(b) voluntary mechanism.
Identify that Section 314(b) provides safe harbor protection for financial institutions to share information voluntarily with each other regarding money laundering.
Section 314(b) creates statutory immunity for private peer-to-peer compliance collaboration.
3
Evaluate the FinCEN Customer Due Diligence (CDD) rule parameters.
Identify that legal entity accounts require verification of all natural persons owning 25%25\% or more equity plus one managerial control person.
CDD rules prevent illicit actors from hiding behind shell company ownership structures.
4
Differentiate cross-border physical currency filings.
Identify that FinCEN Form 105 (CMIR) is specific to physical transport or mailing of currency/instruments exceeding $10,000\$10,000 into or out of the U.S.
Cross-border movements of physical currency require specialized Treasury reporting separate from domestic branch cash CTR filings.

Key Concept

USA PATRIOT Act Information Sharing Protocols and FinCEN Customer Due Diligence Mandates
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Topics

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