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

Under FINRA rules and the USA PATRIOT Act, member broker-dealers must implement Customer Identification Programs (CIP) and comply with Office of Foreign Assets Control (OFAC) sanctions. When opening a new individual brokerage account, which of the following represent mandatory compliance obligations? Select ALL that apply.

  1. Obtaining the customer's full legal name, date of birth, residential street address, and taxpayer identification number prior to account openingCevap
  2. Screening the prospective customer's name against the OFAC Specially Designated Nationals (SDN) list to block unauthorized accountsCevap
  3. C
    Filing a Suspicious Activity Report (SAR) within 15 calendar days whenever a prospective customer fails to provide a tax identification number
  4. D
    Submitting a Currency Transaction Report (CTR) to FinCEN for any initial account deposit exceeding $5,000 made via personal check

Cevap

The mandatory obligations when opening an individual customer account are acquiring the four required CIP identification items (name, date of birth, street address, and tax ID) and screening the client against the OFAC Specially Designated Nationals (SDN) list.
Under federal AML rules and the USA PATRIOT Act, broker-dealers must establish a written Customer Identification Program (CIP) that requires obtaining four core customer data points prior to account opening: legal name, date of birth, residential street address, and taxpayer identification number (or government ID for non-U.S. citizens). Additionally, member firms must comply with OFAC sanctions by screening all prospective clients against the Specially Designated Nationals (SDN) list. The option stating a SAR must be filed within 15 days for a missing TIN is incorrect because SAR filings have a 30-day deadline. The option proposing a CTR for check deposits over 5,000isincorrectbecauseCTRsapplyexclusivelytophysicalcashexceeding5,000 is incorrect because CTRs apply exclusively to physical cash exceeding 10,000.

Adım Adım Çözüm

1
Review mandatory Customer Identification Program (CIP) requirements under the USA PATRIOT Act.
The broker-dealer must collect four specific pieces of identifying information before account opening: legal name, date of birth (for individuals), residential or business street address, and tax identification number.
Federal law mandates these four baseline pieces of identification to verify customer identity and prevent money laundering.
2
Evaluate Office of Foreign Assets Control (OFAC) sanctions screening rules.
Firms must cross-examine all customer names against the OFAC Specially Designated Nationals (SDN) list.
U.S. financial institutions are prohibited from doing business with targeted terrorists, drug traffickers, and foreign countries subject to sanctions.
3
Differentiate Currency Transaction Report (CTR) and Suspicious Activity Report (SAR) filing rules to eliminate false options.
CTRs apply to physical cash transactions exceeding 10,000(15−dayfilinglimit),whileSARsapplytosuspicioustransactionsof10,000 (15-day filing limit), while SARs apply to suspicious transactions of 5,000 or more (30-day filing limit). Personal checks do not trigger CTRs.
Confusing cash CTR thresholds (10,000/15days)withSARsuspiciousactivitylimits(10,000 / 15 days) with SAR suspicious activity limits ( 5,000 / 30 days) is a common procedural misconception.

Anahtar Kavram

Customer Identification Program (CIP) baseline data rules and OFAC SDN sanctions list verification.
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Konular

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