Examkin

Soru

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

A registered representative detects a series of unusual journal transfers totaling $8,000 between two unrelated customer accounts. The transfers have no discernible economic purpose or business rationale. After internal escalation, the broker-dealer's compliance department determines that suspicious activity has occurred. Which of the following statements correctly identifies the firm's reporting obligation under federal Anti-Money Laundering (AML) regulations?

  1. The firm must file a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days and is strictly prohibited from 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 transaction amount exceeds $5,000.
  3. C
    The firm must file a Suspicious Activity Report (SAR) with FinCEN within 15 calendar days and send a copy of the report to the account holder.
  4. D
    The firm must file a Currency Transaction Report (CTR) with FinCEN within 30 calendar days after notifying the customer in writing.

Cevap

The firm must file a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days and is strictly prohibited from disclosing the filing to the customer.
Under Bank Secrecy Act and FINRA rules, broker-dealers must file a Suspicious Activity Report (SAR) with FinCEN whenever a transaction (or series of transactions) involves at least $5,000 and lacks a legitimate business or lawful purpose. The report must be submitted within 30 calendar days of detecting the suspicious behavior. Furthermore, federal law strictly forbids disclosing to the customer that a SAR has been filed.

Adım Adım Çözüm

1
Identify the nature of the transaction and applicable report.
The activity involves journal transfers between unrelated accounts totaling $8,000 with no business purpose, requiring a Suspicious Activity Report (SAR) rather than a Currency Transaction Report (CTR), because no physical currency (cash) was deposited or withdrawn.
SARs apply to suspicious transactions involving 5,000ormore,whereasCTRsapplyexclusivelytophysicalcashtransactionsexceeding5,000 or more, whereas CTRs apply exclusively to physical cash transactions exceeding 10,000.
2
Determine the legal filing deadline for a SAR.
A SAR must be filed with the Financial Crimes Enforcement Network (FinCEN) within 30 calendar days of discovering the suspicious activity.
Federal regulation under the Bank Secrecy Act establishes a standard 30-calendar-day window for filing SARs once suspicious activity is detected.
3
Verify confidentiality regulations regarding SAR submissions.
The firm and its employees must maintain strict secrecy regarding the filing.
It is a federal violation to inform any person involved in the transaction that a SAR has been or will be filed.

Anahtar Kavram

Suspicious Activity Report (SAR) Thresholds, Deadlines, and Confidentiality Rules
Bu soruyu puanla

Konular

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