During an internal audit, a broker-dealer identifies two distinct transactions involving a newly opened customer account: first, a single physical currency deposit of $12,000; second, an attempted outgoing wire transfer to an individual listed on the OFAC Specially Designated Nationals and Blocked Persons (SDN) List. Which of the following compliance actions must the member firm take in response to these events? (Select all that apply)
- File a Currency Transaction Report (CTR) with FinCEN within 15 calendar days of the physical currency transactionCevap
- Block the wire transfer immediately and submit a report to OFAC within 10 business daysCevap
- CFile a Suspicious Activity Report (SAR) within 15 calendar days based solely on the cash deposit exceeding $10,000
- DNotify the account holder in writing that a Suspicious Activity Report (SAR) is being prepared regarding the transactions
Cevap
The firm must file a Currency Transaction Report (CTR) within 15 calendar days for the cash deposit exceeding $10,000 and block the SDN wire transfer while reporting it to OFAC within 10 business days.
Under anti-money laundering and sanctions compliance rules, receiving physical currency exceeding $10,000 obligates the firm to file a Currency Transaction Report (CTR) with FinCEN within 15 calendar days. Simultaneously, any transaction attempt associated with an entity listed on OFAC's Specially Designated Nationals (SDN) List requires the broker-dealer to immediately block the transaction and submit a formal report to OFAC within 10 business days.
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AML Reporting Thresholds, Timelines, and Sanctions Blocking Rules