A broker-dealer compliance team is updating its written supervisory procedures regarding customer onboarding, Anti-Money Laundering (AML), and regulatory filings. Which of the following statements regarding Customer Identification Program (CIP), Currency Transaction Report (CTR), Suspicious Activity Report (SAR), and Office of Foreign Assets Control (OFAC) compliance obligations are correct?
- Customer Identification Program (CIP) identity verification records must be retained by the broker-dealer for at least five years after the customer's account is closed.Cevap
- BA broker-dealer is required to file a Currency Transaction Report (CTR) within 15 calendar days whenever a customer deposits $8,500 in physical cash in a single business day.
- Broker-dealers must check prospective customers against OFAC lists, including the Specially Designated Nationals (SDN) list, to prevent transactions with sanctioned entities and individuals.Cevap
- DA Suspicious Activity Report (SAR) must be filed with FinCEN only when a transaction involving physical currency exceeds $10,000.
Cevap
The correct statements are that Customer Identification Program (CIP) records must be maintained for 5 years after account closure, and that firms must check prospective customers against OFAC lists such as the Specially Designated Nationals (SDN) list.
Under Bank Secrecy Act and FINRA regulations, CIP records (including verification of customer names, DOB, address, and TIN) must be retained for 5 years after the date the account is closed. Furthermore, firms are legally required to consult OFAC sanctions databases—specifically the Specially Designated Nationals (SDN) list—to freeze assets or block accounts of designated persons.
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Anahtar Kavram
Understanding key AML thresholds, CIP record retention timelines, and OFAC sanctions screening obligations.