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Question

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

A compliance officer at a FINRA member broker-dealer is reviewing firm operations to ensure full adherence to federal Anti-Money Laundering (AML) laws and Bank Secrecy Act requirements. Which of the following statements regarding Currency Transaction Report (CTR) filing rules are correct?

  1. A CTR must be filed with FinCEN whenever a single customer conducts cash transactions exceeding $10,000 during a single business day.Answer
  2. Multiple cash deposits made at different branch offices of the same broker-dealer on the same business day must be aggregated when calculating the threshold.Answer
  3. C
    A CTR must be filed within 30 calendar days whenever any suspicious equity securities transfer valued at $5,000 or more takes place.
  4. D
    Standard personal checks and wire transfers exceeding $10,000 automatically trigger a CTR filing.

Answer

The correct statements are that a CTR must be filed when physical currency transactions exceed $10,000 in a single business day for a customer, and that multiple cash deposits made across different branch offices of the same firm on the same day must be aggregated to determine whether the threshold is met.
The statements regarding cash transactions exceeding 10,000inasinglebusinessdayandaggregatingmultiplecashdepositsmadeatdifferentbranchofficesofthesamefirmarecorrect.CTRrulesrequirefinancialinstitutionstoreportphysicalcurrencydeposits,withdrawals,orexchangesexceeding10,000 in a single business day and aggregating multiple cash deposits made at different branch offices of the same firm are correct. CTR rules require financial institutions to report physical currency deposits, withdrawals, or exchanges exceeding 10,000 in a single business day, and firms are legally required to combine all cash transactions made by the same customer on that day.

Step-by-Step Solution

1
Identify the specific AML report being evaluated
The question specifically asks about Currency Transaction Report (CTR) obligations.
Different AML reports (CTR vs. SAR) have distinct monetary thresholds, filing triggers, and instrument types.
2
Verify CTR monetary thresholds and triggering instruments
CTRs are triggered specifically by physical currency/cash transactions exceeding $10,000 in a single business day. Personal checks and electronic wire transfers do not trigger CTR filings.
The Bank Secrecy Act requires tracking of paper money and coin movements into or out of financial institutions.
3
Evaluate aggregation rules across firm locations
Firms must aggregate all cash transactions conducted by or on behalf of the same person across all branches during one business day.
Aggregation prevents evasion of reporting requirements through multiple smaller cash deposits across different branch locations.

Key Concept

Currency Transaction Report (CTR) Rules and Thresholds
Estimated Time:1m 0s
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Topics

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