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

An investor deposits $15,000 in physical currency into an account at a member firm in a single business day. Under federal Anti-Money Laundering (AML) regulations, which report is the broker-dealer required to file with FinCEN, and within what timeframe?

  1. A Currency Transaction Report (CTR) within 15 calendar days of the transactionCevap
  2. B
    A Suspicious Activity Report (SAR) within 30 calendar days of the transaction
  3. C
    A Currency Transaction Report (CTR) within 30 calendar days of the transaction
  4. D
    A Suspicious Activity Report (SAR) within 15 calendar days of the transaction

Cevap

The broker-dealer must file a Currency Transaction Report (CTR) with FinCEN within 15 calendar days of the currency transaction.
Under the Bank Secrecy Act (BSA), broker-dealers are required to file a Currency Transaction Report (CTR) with FinCEN for any physical cash or currency transaction exceeding $10,000 in a single business day. The filing must be submitted within 15 calendar days of the transaction.

Adım Adım Çözüm

1
Identify the transaction type and amount
The customer deposited $15,000 in physical currency in a single day.
Federal AML rules specify reporting requirements based on transaction medium and amount.
2
Determine the required regulatory filing based on monetary thresholds
Since physical cash deposits exceed $10,000 in a single day, a Currency Transaction Report (CTR) is mandatory.
CTRs apply to cash/currency transactions over 10,000,whereasSARsapplytosuspicioustransactionsof10,000, whereas SARs apply to suspicious transactions of 5,000 or more.
3
Identify the federal filing deadline for the report
A CTR must be filed within 15 calendar days with the Financial Crimes Enforcement Network (FinCEN).
15 calendar days is the statutory deadline for CTR submissions under the Bank Secrecy Act.

Anahtar Kavram

Currency Transaction Report (CTR) threshold ($10,000+ in cash) and filing deadline (15 calendar days)
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