A compliance officer at a FINRA member broker-dealer is reviewing the firm's Anti-Money Laundering (AML) policy manual. Under federal law and FINRA rules, which of the following statements regarding AML compliance obligations are CORRECT? (Select ALL that apply.)
- A Currency Transaction Report (CTR) must be filed for cash deposits or withdrawals exceeding $10,000 in a single business day.Cevap
- Member firms must designate a qualified person to oversee and implement the firm's AML compliance program.Cevap
- CA Suspicious Activity Report (SAR) is only required for suspicious transactions involving cash exceeding $10,000.
- DSuspicious Activity Reports (SARs) are submitted directly to the Internal Revenue Service (IRS) within 15 calendar days.
Cevap
The statements confirming that Currency Transaction Reports (CTRs) are required for cash transactions exceeding $10,000 in a single business day and that broker-dealers must designate an AML compliance supervisor are correct.
Currency Transaction Reports (CTRs) are triggered by physical currency transactions exceeding $10,000 in a single business day. Furthermore, FINRA Rule 3310 requires member firms to designate an individual (AML Compliance Officer) to monitor and administer the firm's anti-money laundering program.
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Anti-Money Laundering (AML) Reporting Thresholds and Supervision