Examkin

Soru

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

A retail client makes three separate cash deposits of 3,500,3,500, 4,000, and $3,800 into a brokerage account across three consecutive business days. During the transactions, the client repeatedly asks the registered representative if any single deposit will be reported to the federal government. The broker-dealer suspects the client is intentionally splitting cash deposits to avoid triggering currency reporting thresholds. Under Bank Secrecy Act (BSA) and FINRA rules, which regulatory filing must the firm complete?

  1. File a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days of identifying the activity.Cevap
  2. B
    File a Currency Transaction Report (CTR) with FinCEN within 30 calendar days based on the $5,000 suspicious threshold.
  3. C
    File a Suspicious Activity Report (SAR) only if a single cash transaction exceeds $10,000 within a 15-day window.
  4. D
    File an OFAC Blocked Property Report within 10 business days of detecting the structured cash deposits.

Cevap

The firm must file a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days of detecting the suspicious structuring activity.
Structuring involves intentionally breaking up cash transactions into amounts below 10,000toavoidtriggeringaCurrencyTransactionReport(CTR).Becausestructuringindicatespotentialillegalactivityandexceedsthe10,000 to avoid triggering a Currency Transaction Report (CTR). Because structuring indicates potential illegal activity and exceeds the 5,000 threshold for suspicious transactions, broker-dealers are required to file a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days of discovering the activity.

Adım Adım Çözüm

1
Identify the nature of the transaction activity.
The client is depositing cash in amounts under $10,000 while asking questions to avoid detection, which constitutes currency structuring.
Structuring is illegal under the Bank Secrecy Act and is designed to evade mandatory reporting.
2
Determine the monetary threshold and correct reporting instrument.
The total amount (11,300)exceedsthe11,300) exceeds the 5,000 SAR threshold for suspicious activity.
Broker-dealers are required to file a SAR for any transaction or series of transactions involving $5,000 or more if the firm knows or suspects money laundering or structuring.
3
Determine the mandatory regulatory filing timeline.
A SAR must be filed with FinCEN within 30 calendar days of initial discovery of the suspicious activity.
Federal AML regulations set a strict 30-calendar-day deadline for filing SARs upon detection.

Anahtar Kavram

Suspicious Activity Report (SAR) Thresholds and Filing Deadlines
Bu soruyu puanla

Konular

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