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

A broker-dealer receives a single physical cash deposit of 15,000intoacustomer′stradingaccountonMonday.Thefollowingweek,thecompliancedepartmentdetectsaseriesofjournaltransferstotaling15,000 into a customer's trading account on Monday. The following week, the compliance department detects a series of journal transfers totaling 8,000 from the same account to an unrelated third-party entity, which the compliance principal determines has no reasonable business or lawful purpose. Under federal anti-money laundering (AML) regulations and FINRA rules, which statement correctly describes the firm's required reporting obligations?

  1. The firm must file a Currency Transaction Report (CTR) within 15 calendar days for the cash deposit and a Suspicious Activity Report (SAR) within 30 calendar days for the journal transfers.Cevap
  2. B
    The firm must file a Suspicious Activity Report (SAR) within 15 calendar days for the cash deposit and a Currency Transaction Report (CTR) within 30 calendar days for the journal transfers.
  3. C
    The firm must file a Currency Transaction Report (CTR) for both transactions within 30 calendar days while immediately notifying the Securities and Exchange Commission.
  4. D
    The firm must file a Suspicious Activity Report (SAR) covering both transactions within 15 calendar days and notify the client in writing within 5 business days.

Cevap

The firm must file a Currency Transaction Report (CTR) within 15 calendar days for the cash deposit and a Suspicious Activity Report (SAR) within 30 calendar days for the journal transfers.
The answer stating that the firm must file a CTR within 15 calendar days for the cash deposit and a SAR within 30 calendar days for the journal transfers is correct. Currency Transaction Reports (FinCEN Form 112) must be submitted within 15 calendar days whenever a single cash deposit exceeds 10,000inabusinessday.SuspiciousActivityReports(FinCENForm111)mustbesubmittedwithin30calendardaysofidentifyingsuspicioustransactionsof10,000 in a business day. Suspicious Activity Reports (FinCEN Form 111) must be submitted within 30 calendar days of identifying suspicious transactions of 5,000 or more with no legitimate economic purpose.

Adım Adım Çözüm

1
Analyze the cash transaction requirement
The physical cash deposit of 15,000exceedsthe15,000 exceeds the 10,000 threshold for cash transactions in a single business day, requiring a Currency Transaction Report (CTR) filed with FinCEN within 15 calendar days.
Bank Secrecy Act (BSA) rules mandate reporting for cash/currency transactions exceeding $10,000.
2
Analyze the suspicious journal transfer requirement
The 8,000journaltransferlacksalawful/commercialpurposeandexceedsthe8,000 journal transfer lacks a lawful/commercial purpose and exceeds the 5,000 threshold for suspicious activity reporting, requiring a Suspicious Activity Report (SAR) filed with FinCEN within 30 calendar days.
FinCEN regulations mandate SAR filings for suspicious transactions totaling $5,000 or more once detected.
3
Verify disclosure and authority rules
Firms must maintain strict confidentiality and never inform the customer about SAR filings.
Tipping off a client regarding a SAR filing violates federal law.

Anahtar Kavram

AML Reporting Thresholds and Deadlines (CTR vs SAR)
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Konular

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