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

A registered representative at a broker-dealer receives an urgent request from an existing retail customer to initiate an outbound wire transfer of $12,500 to a foreign corporate account. The customer specifically asks the representative to omit their permanent residential address and taxpayer identification number from the wire transmission fields to 'speed up international routing.' Additionally, an automated check against the Department of the Treasury's Office of Foreign Assets Control (OFAC) database reveals that the targeted foreign beneficiary is listed on the Specially Designated Nationals and Blocked Persons (SDN) List. Under federal Anti-Money Laundering (AML) regulations and sanctions compliance rules, which of the following actions must the broker-dealer take?

  1. Block the transaction immediately, report the blocked assets to OFAC within 10 business days, and file a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days.Cevap
  2. B
    Process the wire transfer as requested, but file a Currency Transaction Report (CTR) with FinCEN within 15 calendar days because the dollar amount exceeds $10,000.
  3. C
    Reject the wire transfer and return the funds to the customer's bank account within 24 hours, while filing a SAR with FinCEN within 15 calendar days.
  4. D
    Allow the wire transfer to proceed because the sender is an established customer, but place a temporary 15-day hold on the entire brokerage account under senior investor protection rules.

Cevap

The broker-dealer must block the wire transfer immediately, report the blocked property to OFAC within 10 business days, and file a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days.
When a firm identifies a match against the OFAC Specially Designated Nationals (SDN) List, federal law mandates that the transaction be immediately blocked (frozen). The firm is required to report the blocked property to OFAC within 10 business days. Additionally, attempting to transact with an SDN entity and requesting the removal of customer identifying data are clear red flags for suspicious activity exceeding the $5,000 threshold, which requires filing a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days.

Adım Adım Çözüm

1
Evaluate the OFAC sanctions match requirement.
Any transaction involving a entity on the OFAC Specially Designated Nationals (SDN) List must be blocked (frozen) immediately upon discovery.
U.S. financial institutions are prohibited from facilitating transactions or releasing funds to individuals or entities on the SDN list.
2
Determine the reporting obligation and timeline for OFAC sanctions enforcement.
The firm must submit an OFAC Report of Blocked Transactions within 10 business days of the blocking action.
Federal regulation mandates prompt notification to the U.S. Treasury's Office of Foreign Assets Control regarding blocked property.
3
Analyze the suspicious activity reporting requirements under FinCEN rules.
The customer's request to omit identifying information combined with an SDN match constitutes suspicious activity exceeding the $5,000 threshold, requiring a SAR filing within 30 calendar days.
Broker-dealers must report known or suspected violations of federal law or suspicious transactions of $5,000 or more to FinCEN within 30 calendar days.

Anahtar Kavram

OFAC Sanctions Compliance and SAR Filing Thresholds
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Konular

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