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

During the opening of a new individual brokerage account, a member firm's compliance department performs Customer Identification Program (CIP) verification and identifies a confirmed match between the applicant and an entry on the Specially Designated Nationals and Blocked Persons (SDN) list. Under regulations administered by the Office of Foreign Assets Control (OFAC), which of the following actions is the member firm required to take?

  1. Block the customer's funds and property, and report the match to OFAC within 10 business days.Cevap
  2. B
    Reject the account application and return all deposited funds to the customer within 30 calendar days.
  3. C
    Open the account under restricted status and file a Suspicious Activity Report (SAR) with FinCEN within 15 calendar days.
  4. D
    Notify the Internal Revenue Service (IRS) and FINRA within 24 hours to initiate a formal criminal prosecution.

Cevap

The member firm must block the customer's funds and property and report the match to OFAC within 10 business days.
When a firm confirms a match on the OFAC Specially Designated Nationals (SDN) list, U.S. law requires the firm to immediately block (freeze) any property or funds associated with the blocked party. The firm must then submit a report of the blocked property to OFAC within 10 business days.

Adım Adım Çözüm

1
Identify the regulatory authority governing the Specially Designated Nationals (SDN) list.
The Office of Foreign Assets Control (OFAC), an agency of the U.S. Department of the Treasury, enforces economic and trade sanctions.
Broker-dealers must check new and existing customer identities against OFAC's SDN list.
2
Determine the mandatory asset action required upon confirming an SDN list match.
All property, accounts, and funds belonging to the blocked individual must be immediately blocked (frozen).
Federal law strictly prohibits transferring funds or providing financial services to individuals on the SDN list.
3
Identify the required reporting timeframe to OFAC.
The firm must report blocked assets to OFAC within 10 business days of taking the blocking action.
OFAC regulations specify a 10-business-day deadline for submitting reports of blocked property.

Anahtar Kavram

Anti-Money Laundering (AML), KYC, and Sanctions Compliance
Tahmini Süre:1m 30s
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Anti-Money Laundering (AML), KYC, and Sanctions Compliance