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

Match each Anti-Money Laundering (AML) or sanctions compliance mandate with its primary regulatory obligation:

  • USA PATRIOT Act Customer Identification Program (CIP)Mandates verifying individual identity using four minimum required data points (name, date of birth, physical address, and TIN/SSN) at account opening.
  • OFAC Specially Designated Nationals (SDN) Sanctions ScreeningRequires blocking or freezing assets and reporting blocked transactions within 1010 business days when matching listed prohibited entities.
  • FinCEN Customer Due Diligence (CDD) Beneficial Ownership RuleRequires broker-dealers to identify and verify natural persons owning 25%25\% or more equity interest in legal entity customers.
  • FINRA Rule 3310 AML Independent Testing MandateRequires periodic independent testing of the firm's compliance program conducted by qualified personnel outside the AML compliance function.

Cevap

The Customer Identification Program (CIP) matches identity verification using four minimum data elements (name, DOB, address, TIN). OFAC SDN screening matches asset blocking and reporting within 1010 business days. FinCEN CDD rule matches identifying beneficial owners with 25%25\% or more equity interest in legal entities. FINRA Rule 3310 matches independent program testing conducted by personnel independent of AML compliance staff.
The correct pairings accurately reflect key federal compliance frameworks under FINRA and Treasury rules: CIP mandates four identity attributes (Name, DOB, Address, TIN); OFAC SDN mandates blocking property and notifying OFAC within 1010 business days; CDD rules set a 25%25\% equity threshold for legal entity beneficial owners; and FINRA Rule 3310 mandates independent testing by non-AML staff.

Adım Adım Çözüm

1
Analyze Customer Identification Program (CIP) requirements
Identify that CIP requires verifying four essential customer items (Name, Date of Birth, Physical Address, and Social Security Number or Taxpayer ID Number).
CIP ensures broker-dealers form a reasonable belief regarding the true identity of every customer.
2
Analyze OFAC SDN screening obligations
Identify that matches to the Specially Designated Nationals list require freezing funds and filing a report with OFAC within 1010 business days.
OFAC enforces economic and trade sanctions targeting targeted foreign countries and regimes.
3
Analyze FinCEN CDD legal entity rules
Identify that legal entity ownership verification requires identifying any natural person with a 25%25\% or greater equity interest.
CDD rules prevent illicit actors from abusing anonymous corporate structures.
4
Analyze FINRA AML program testing rules
Identify that FINRA Rule 3310 requires independent testing of the firm's AML system by personnel not involved in carrying out the AML program.
Independent testing ensures objective evaluation of the firm's compliance controls.

Anahtar Kavram

Anti-Money Laundering (AML), Customer Identification, and Sanctions Compliance Obligations
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Konular

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