Examkin

Soru

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

A compliance officer at a member broker-dealer identifies a pattern of wire transfers totaling $7,500 between unrelated account holders that appears to have no legitimate business or commercial purpose. After completing an internal investigation, the firm concludes the activity is suspicious. Under Bank Secrecy Act and FINRA Anti-Money Laundering (AML) rules, which of the following actions is the firm required to take?

  1. File a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days without disclosing the filing to the customer.Cevap
  2. B
    File a Currency Transaction Report (CTR) with FinCEN within 15 calendar days of the final wire transfer.
  3. C
    File a Suspicious Activity Report (SAR) with FinCEN within 15 calendar days and send written notice to the involved account holders.
  4. D
    File a Currency Transaction Report (CTR) with FinCEN within 30 calendar days only if total transactions exceed $10,000.

Cevap

The firm must file a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days of discovering the activity and must strictly maintain confidentiality by not notifying the customer.
Under federal Anti-Money Laundering (AML) regulations and FINRA rules, broker-dealers must file a Suspicious Activity Report (SAR) for any transaction involving $5,000 or more if the firm suspects money laundering, structuring, or lack of legitimate business purpose. The firm must submit the report to FinCEN within 30 calendar days of discovering the suspicious pattern and is legally prohibited from disclosing the report to the customer.

Adım Adım Çözüm

1
Identify the transaction type and reporting threshold requirement.
The activity involves wire transfers totaling 7,500suspectedofmoneylaundering,whichmeetstheSARthresholdof7,500 suspected of money laundering, which meets the SAR threshold of 5,000 or more.
Suspicious Activity Reports (SARs) cover any transaction type (cash, check, wire) involving at least $5,000 where illicit activity is suspected.
2
Determine the mandatory filing timeline and confidentiality constraints.
The SAR must be filed with FinCEN within 30 calendar days of detection, and disclosure to the customer is legally prohibited.
Federal law mandates a 30-calendar-day window for filing SARs and prohibits tipping off subjects of SAR reports.

Anahtar Kavram

Suspicious Activity Report (SAR) Thresholds and Filing Requirements
Bu soruyu puanla

Konular

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