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

A retail customer makes two physical cash deposits of 6,000eachintoanewlyopenedbrokerageaccountovertwoconsecutivebusinessdays,resultinginanaggregatecashdepositof6,000 each into a newly opened brokerage account over two consecutive business days, resulting in an aggregate cash deposit of 12,000. Which of the following compliance actions must the broker-dealer take under federal regulations?

  1. Submit a Currency Transaction Report (CTR) to FinCEN within 15 calendar days.Cevap
  2. B
    Submit a Suspicious Activity Report (SAR) to FINRA within 30 calendar days because cash deposits exceed $5,000.
  3. C
    Submit a Currency Transaction Report (CTR) directly to the Securities and Exchange Commission (SEC) within 30 calendar days.
  4. D
    Maintain internal firm records without filing a federal report, as cash reporting thresholds only apply to single transactions exceeding $15,000.

Cevap

The broker-dealer must submit a Currency Transaction Report (CTR) to FinCEN within 15 calendar days of the transaction.
The correct answer identifies that physical cash transactions exceeding $10,000 in a single day or aggregated across related transactions mandate the filing of a Currency Transaction Report (CTR) with FinCEN within 15 calendar days.

Adım Adım Çözüm

1
Identify the transaction type and cumulative monetary amount.
The client deposited $12,000 in total physical currency across consecutive days.
Physical currency transactions aggregating to more than $10,000 trigger mandatory currency reporting under the Bank Secrecy Act.
2
Determine the required regulatory report and agency.
A Currency Transaction Report (CTR) must be submitted to the Financial Crimes Enforcement Network (FinCEN).
FinCEN is the U.S. Treasury bureau responsible for collecting and processing CTR filings.
3
Determine the legal filing deadline.
The CTR must be filed within 15 calendar days of the qualifying deposit.
Federal anti-money laundering regulations mandate a 15-calendar-day deadline for CTR submissions.

Anahtar Kavram

Currency Transaction Report (CTR) thresholds, agency, and timelines
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Konular

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