A broker-dealer compliance department is reviewing its procedures for Customer Identification Programs (CIP), Suspicious Activity Reports (SAR), and Office of Foreign Assets Control (OFAC) sanctions compliance. Which of the following statements regarding these regulatory obligations are correct?
- Under CIP rules, a member firm must verify the identity of each customer within a reasonable time before or after the customer account is opened.Cevap
- If a prospective client's name matches an entity on the OFAC Specially Designated Nationals (SDN) list, the broker-dealer must block or reject the transaction and report the match within 10 business days.Cevap
- CA Currency Transaction Report (CTR) must be filed with FinCEN within 30 calendar days whenever a customer conducts cash deposits aggregating over $5,000 in a single business day.
- DWhen a firm files a Suspicious Activity Report (SAR) concerning an account, it is required to notify the customer in writing within 15 days of the filing.
Cevap
The correct statements are that CIP rules allow identity verification within a reasonable timeframe before or after account opening, and OFAC SDN list matches require blocking assets and filing a report within 10 business days.
The statements regarding CIP verification timeframe (reasonable time before/after opening) and OFAC SDN blocking/reporting requirements (asset freeze and 10 business day report) accurately reflect FINRA, FinCEN, and OFAC regulations.
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Anahtar Kavram
Anti-Money Laundering (AML), KYC, and Sanctions Compliance Obligations