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

A compliance analyst at a member broker-dealer discovers an outgoing international wire transfer request of $45,000 to a recipient identified on the Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons (SDN) list. Under federal sanctions regulations, which of the following actions is the firm required to take?

  1. Block the transaction immediately and report the blocked wire to OFAC within 10 business days.Cevap
  2. B
    Reject the wire transfer request and notify the customer in writing that their recipient appears on a federal sanctions watch list.
  3. C
    Process the wire transfer, but file a Currency Transaction Report (CTR) with the Internal Revenue Service within 15 calendar days.
  4. D
    Cancel the wire transfer and submit a Suspicious Activity Report (SAR) directly to FINRA within 30 calendar days as the sole compliance measure.

Cevap

The firm must block the transaction immediately and report the blocked wire to OFAC within 10 business days.
Under U.S. federal sanctions regulations administered by the Treasury Department's Office of Foreign Assets Control (OFAC), broker-dealers are required to check customer accounts and transactions against the Specially Designated Nationals and Blocked Persons (SDN) list. If a match is verified, the firm must immediately block (freeze) the transaction/assets and report the action to OFAC within 10 business days.

Adım Adım Çözüm

1
Identify the compliance mandate associated with an OFAC SDN list match.
OFAC sanctions rules require financial institutions to screen transactions against the SDN list.
Transactions involving prohibited countries, regimes, or targeted individuals/entities on the SDN list cannot be completed.
2
Determine the required action regarding the customer's funds.
The firm must block (freeze) the property/funds involved in the transaction.
Firms cannot return or process funds destined for an SDN-listed recipient; the funds must be placed into an interest-bearing blocking account.
3
Determine the regulatory filing destination and timeline.
The firm must submit a report to OFAC within 10 business days of the blocking action.
Federal law specifies a 10-business-day reporting window directly to OFAC for blocked or rejected transactions.

Anahtar Kavram

OFAC Sanctions Compliance and SDN List Blocking Obligations
Tahmini Süre:1m 0s
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Konular

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