Examkin

Soru

Zorluk: ZorAnti-Money Laundering (AML), KYC, and Sanctions Compliance

A customer opens a brokerage account at a FINRA member firm by depositing a 15,000personalcheck.Overthefollowingweek,thecustomerexecutesseveralrapidtradesandsubsequentlyrequestsfourseparatewiretransferstotaling15,000 personal check. Over the following week, the customer executes several rapid trades and subsequently requests four separate wire transfers totaling 18,000 to accounts held at foreign banks in high-risk jurisdictions. When the registered representative inquiries about the business purpose of these foreign transfers, the customer provides conflicting responses and becomes highly evasive. Based on Federal anti-money laundering (AML) regulations and FINRA rules, which of the following statements correctly describes the broker-dealer's reporting obligation?

  1. The firm must file a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days of detecting the activity and must maintain strict confidentiality by not disclosing the filing to the customer.Cevap
  2. B
    The firm must file a Currency Transaction Report (CTR) with FinCEN within 15 calendar days because the total amount transferred across the accounts exceeds the $10,000 regulatory threshold.
  3. C
    The firm must file a Suspicious Activity Report (SAR) within 15 calendar days and send written notice to the customer detailing the ongoing AML investigation.
  4. D
    The firm is not required to file a report with FinCEN because the initial deposit was made via personal check rather than physical currency.

Cevap

The firm must file a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days of detecting the suspicious activity and is strictly prohibited from informing the customer of the filing.
Under Bank Secrecy Act (BSA) regulations and FINRA rules, broker-dealers must file a Suspicious Activity Report (SAR) with FinCEN when a transaction involves or totals at least $5,000 in funds or assets and the firm knows, suspects, or has reason to suspect that the transaction involves illegal activity or has no apparent lawful business purpose. The SAR must be filed within 30 calendar days of initial detection. Furthermore, federal law strictly forbids notifying any person involved in the transaction that a SAR has been reported.

Adım Adım Çözüm

1
Analyze the financial instrument and behavior described in the scenario.
The scenario involves wire transfers totaling $18,000 funded initially by check, accompanied by evasive customer behavior and transfers to foreign high-risk jurisdictions.
Identifying red flags and payment methods determines which AML regulatory filing applies.
2
Distinguish between Currency Transaction Report (CTR) and Suspicious Activity Report (SAR) requirements.
CTRs apply strictly to physical currency (cash) deposits or withdrawals exceeding 10,000.SARsapplytosuspicioustransactionsinvolving10,000. SARs apply to suspicious transactions involving 5,000 or more in any monetary asset.
Wire transfers and check deposits are not physical cash, so CTR rules do not apply.
3
Apply SAR filing timelines and confidentiality rules.
A SAR must be filed with the Financial Crimes Enforcement Network (FinCEN) within 30 calendar days of initial discovery, and the customer must never be notified.
Federal rules mandate a 30-day window and strict non-disclosure to protect law enforcement investigations.

Anahtar Kavram

Suspicious Activity Report (SAR) vs. Currency Transaction Report (CTR) Filing Requirements
Tahmini Süre:1m 30s
Bu soruyu puanla

Konular

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