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Question

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

A registered broker-dealer must comply with distinct federal recordkeeping timelines, filing deadlines, and mandatory actions under FinCEN, CIP, and OFAC regulations. Match each compliance event or recordkeeping mandate on the left with its exact statutory requirement or deadline on the right.

  • Initial filing of a Suspicious Activity Report (SAR) upon discovering transactions indicative of potential money laundering where a known suspect is identifiedMust be filed with FinCEN no later than 30 calendar days after the initial date of detection
  • Retention period for identifying information (name, date of birth, address, tax ID) collected from a customer under the firm's Customer Identification Program (CIP)Must be retained for 5 years after the date the customer's account is closed
  • Mandatory reporting window to the Office of Foreign Assets Control (OFAC) after blocking or freezing an asset transfer tied to an entry on the Specially Designated Nationals (SDN) listMust be reported to the regulator within 10 business days of the blocking action
  • Filing deadline for a Currency Transaction Report (CTR) following a customer's aggregate physical cash deposits exceeding $10,000 on a single business dayMust be filed electronically with FinCEN within 15 calendar days of the transaction

Answer

Suspicious Activity Report (SAR) filing with a identified suspect matches 30 calendar days after detection; Customer Identification Program (CIP) core identifier retention matches 5 years after account closure; OFAC SDN asset blocking reporting matches 10 business days from the action; Currency Transaction Report (CTR) filing matches 15 calendar days from the cash transaction date.
Each regulatory requirement matches its exact statutory timeline: SARs with identified suspects must be filed within 30 calendar days of initial detection; CIP customer identifying data must be retained for 5 years after account closure; OFAC blocked asset reports must be filed within 10 business days; and CTRs for cash deposits over $10,000 must be filed within 15 calendar days.

Step-by-Step Solution

1
Analyze SAR filing timeframe requirements
Identify that FinCEN requires SAR filings within 30 calendar days of detection when a known suspect is involved.
BSA regulations set a strict 30-day window from initial detection for broker-dealers.
2
Differentiate CIP record retention rules
Recognize that core identifying information (name, DOB, address, TIN) must be preserved for 5 years post account closure.
FINRA Rule 3310 and BSA regulations distinguish between verification record retention (5 years after creation) and core identity info retention (5 years after account closure).
3
Determine OFAC sanctions reporting requirement
Confirm that blocked asset transfers matching SDN list entries require filing a report within 10 business days.
OFAC compliance mandates immediate freezing of assets and formal notification within 10 business days.
4
Verify Currency Transaction Report (CTR) deadline
Match currency deposits over $10,000 in one business day to the 15 calendar day FinCEN filing rule.
CTR filings (FinCEN Form 112) carry a statutory 15-calendar-day reporting requirement.

Key Concept

AML Filing Timelines, CIP Record Retention, and Sanctions Compliance Deadlines
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Topics

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