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

A compliance officer at a broker-dealer is reviewing written supervisory procedures regarding Customer Identification Programs (CIP), Anti-Money Laundering (AML) reporting, and Office of Foreign Assets Control (OFAC) sanctions compliance. Which of the following statements accurately describe mandatory broker-dealer compliance obligations under federal regulations? Select all that apply.

  1. Verifying the customer's identity through reliable documentary or non-documentary methods within a reasonable time after account opening under the Customer Identification Program (CIP).Cevap
  2. Screening prospective and existing customer accounts against the Specially Designated Nationals (SDN) list maintained by the Office of Foreign Assets Control (OFAC).Cevap
  3. C
    Filing a Currency Transaction Report (CTR) with FinCEN within 30 calendar days whenever a customer conducts a wire transfer of $5,000 or more in a single business day.
  4. D
    Notifying the account holder in writing within 15 calendar days following the submission of a Suspicious Activity Report (SAR) to FinCEN.

Cevap

The statements requiring verification of customer identity within a reasonable timeframe under CIP and screening customer names against the OFAC Specially Designated Nationals list are both correct regulatory obligations.
Verifying customer identities under CIP procedures within a reasonable timeframe and checking account names against the OFAC SDN list to prevent illegal sanctions violations are core mandatory anti-money laundering and sanctions compliance duties for broker-dealers.

Adım Adım Çözüm

1
Evaluate Customer Identification Program (CIP) requirements
Confirm that identity verification via government photo IDs or non-documentary sources is mandatory.
CIP rules dictate that broker-dealers must establish reasonable identity verification procedures for new account holders.
2
Evaluate Office of Foreign Assets Control (OFAC) requirements
Confirm that screening against the SDN list is mandatory.
U.S. persons and financial firms are prohibited from conducting transactions with individuals/entities listed on OFAC's SDN list.
3
Analyze monetary thresholds and filing rules for CTRs and SARs
Identify errors in wire transfer CTR thresholds and SAR customer notification rules.
CTRs apply to cash transactions >10,000(15daydeadline),whileSARsapplytosuspicioustransactions10,000 (15-day deadline), while SARs apply to suspicious transactions ≥ 5,000 (30-day deadline) and require absolute confidentiality.

Anahtar Kavram

AML, CIP, and OFAC Sanctions Obligations
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