A compliance officer at a FINRA member firm is reviewing recent transactions in a newly opened customer account. On Monday, the customer deposited 4,000 in physical currency. In addition, the customer submitted an outgoing wire request to an overseas entity that appears on the U.S. Department of the Treasury's Specially Designated Nationals (SDN) list. Which of the following statements regarding the firm's mandatory compliance and reporting obligations under Anti-Money Laundering (AML) and sanctions rules are correct?
- The firm must immediately block or freeze the wire transfer and file a report with the Office of Foreign Assets Control (OFAC) within 10 business days.Cevap
- The firm must file a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days due to potential structuring and suspicious activity exceeding the $5,000 threshold.Cevap
- CThe firm is required to file a Currency Transaction Report (CTR) because total cash deposits over the two-day period exceeded $5,000.
- DThe firm must wait 15 calendar days before filing a Suspicious Activity Report (SAR) to allow the customer an opportunity to clarify the wire recipient's identity.
Cevap
The firm must immediately block the wire transfer to the SDN-listed entity and report it to OFAC within 10 business days, as well as file a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days for suspicious behavior and potential structuring exceeding $5,000.
Under federal AML and sanctions regulations, matching an entity on the OFAC SDN list requires immediate blocking of the transaction and submitting a report to OFAC within 10 business days. Furthermore, attempts to structure cash deposits or conduct suspicious wire transfers totaling $5,000 or more mandate filing a Suspicious Activity Report (SAR) with FinCEN within 30 calendar days of initial discovery.
Adım Adım Çözüm
Anahtar Kavram
AML and Sanctions Compliance Reporting Thresholds and OFAC Obligations