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

A compliance officer at a broker-dealer is updating the firm's written supervisory procedures regarding Customer Identification Program (CIP) requirements and Office of Foreign Assets Control (OFAC) sanctions compliance. Which of the following statements accurately describe mandatory broker-dealer obligations under these regulations?

  1. The firm must verify the identity of each customer within a reasonable time before or after the account is opened.Cevap
  2. B
    The firm must file a Currency Transaction Report (CTR) for any suspicious activity involving $5,000 or more.
  3. The firm must screen customer names against the OFAC Specially Designated Nationals (SDN) list to prevent transactions with sanctioned individuals.Cevap
  4. D
    If a customer's name matches an OFAC sanctions list, the firm is required to notify the customer immediately before freezing the funds.

Cevap

The correct statements are that broker-dealers must verify customer identities within a reasonable time frame before or after account opening, and must screen customer names against the OFAC Specially Designated Nationals (SDN) list to block transactions involving sanctioned persons.
Under Bank Secrecy Act and USA PATRIOT Act rules, Customer Identification Programs (CIP) require broker-dealers to verify customer identity within a reasonable time before or after account opening. Furthermore, OFAC regulations require firms to screen customers against government watchlists (such as the SDN list) and freeze assets of sanctioned persons.

Adım Adım Çözüm

1
Evaluate CIP identity verification obligations.
Confirm that verifying customer identity within a reasonable time around account opening is mandatory.
CIP regulations require broker-dealers to establish reasonable verification procedures for all new accounts.
2
Distinguish between CTR and SAR monetary thresholds.
Identify that 5,000isthereportingthresholdforaSuspiciousActivityReport(SAR),whereasCurrencyTransactionReports(CTRs)applytocashdeposits/withdrawalsexceeding5,000 is the reporting threshold for a Suspicious Activity Report (SAR), whereas Currency Transaction Reports (CTRs) apply to cash deposits/withdrawals exceeding 10,000.
Confusing SAR and CTR thresholds is a common regulatory calculation error.
3
Evaluate OFAC screening and blocking requirements.
Confirm mandatory SDN list screening and recognize that alerting a blocked entity is strictly prohibited.
OFAC sanctions compliance mandates asset blocking and reporting without tipping off targeted individuals.

Anahtar Kavram

Customer Identification Program (CIP) verification rules and OFAC Sanctions Compliance requirements.
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