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Question

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

A client requests a series of wire transfers totaling $7,500 from a brokerage account to a foreign bank located in a high-risk jurisdiction. The client offers no legitimate business explanation for the transactions, giving the firm reasonable grounds to suspect potential money laundering. Under FinCEN and FINRA regulations, which of the following reporting obligations applies to the broker-dealer?

  1. File a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days of detecting the suspicious activity.Answer
  2. B
    File a Currency Transaction Report (CTR) with FinCEN within 15 calendar days because the transfers exceed $5,000.
  3. C
    File a Currency Transaction Report (CTR) within 30 calendar days because international wire transfers automatically trigger CTR obligations.
  4. D
    Refrain from filing any regulatory report because mandatory anti-money laundering reporting only applies to cash transactions exceeding $10,000.

Answer

The broker-dealer must file a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days of discovering the suspicious activity.
Under Anti-Money Laundering (AML) rules administered by FinCEN and enforced by FINRA, broker-dealers must file a Suspicious Activity Report (SAR) whenever a transaction (or series of transactions) involves or totals at least $5,000 and the firm suspects illegal activity, money laundering, or lack of apparent business purpose. The firm must submit the SAR within 30 calendar days of initial discovery.

Step-by-Step Solution

1
Determine the type of transaction and reporting trigger
The scenario involves suspicious wire transfers totaling $7,500 without a clear business purpose.
Suspicious transactions involving funds or assets of $5,000 or more trigger a mandatory Suspicious Activity Report (SAR) requirement under the Bank Secrecy Act and FinCEN rules.
2
Distinguish between SAR and CTR reporting rules
A Currency Transaction Report (CTR) applies only to physical cash (currency) transactions exceeding $10,000 within a single business day, not wire transfers.
Wire transfers are electronic fund movements, not physical cash transactions.
3
Identify the mandatory filing timeframe for a SAR
A SAR must be filed with FinCEN within 30 calendar days after the initial detection of suspicious activity.
This complies with federal Anti-Money Laundering (AML) regulatory compliance timelines.

Key Concept

Suspicious Activity Report (SAR) vs. Currency Transaction Report (CTR) Thresholds and Timelines
Estimated Time:1m 0s
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Topics

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