Question

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

An investor visits a broker-dealer branch and deposits $14,000 in physical cash into a brokerage account during a single business day. Which report must the member firm file to comply with Financial Crimes Enforcement Network (FinCEN) regulations?

  1. A Currency Transaction Report (CTR) within 15 calendar daysAnswer
  2. B
    A Suspicious Activity Report (SAR) within 30 calendar days
  3. C
    A Currency Transaction Report (CTR) within 30 calendar days
  4. D
    A Customer Identification Program (CIP) log within 5 business days

Answer

A Currency Transaction Report (CTR) must be filed within 15 calendar days.
Under FinCEN and Bank Secrecy Act rules, member firms must file a Currency Transaction Report (CTR) for any customer cash deposit, withdrawal, or exchange exceeding $10,000 in a single business day. The CTR must be filed within 15 calendar days of the transaction.

Step-by-Step Solution

1
Identify the transaction type and monetary amount
The deposit consists of $14,000 in physical cash within a single business day.
Currency Transaction Reports (CTRs) apply specifically to physical currency transactions exceeding $10,000.
2
Determine the appropriate reporting requirement and deadline
Under the Bank Secrecy Act and FinCEN regulations, broker-dealers must file a CTR for physical cash deposits over $10,000 within 15 calendar days of the transaction.
Standard cash transactions over the threshold trigger routine CTR reporting rather than SAR reporting, unless suspicious behavior or structuring is observed.

Key Concept

Currency Transaction Report (CTR) Requirements
Estimated Time:45s
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