Identifying and Escalating Suspicious Activity
Chapters in this video
- 0:00 Why broker-dealers monitor for suspicious activity
- 1:47 SAR $5,000 threshold and the four suspicion triggers
- 2:53 RR escalates, AMLCO files: the 30-day clock and no-tipping rule
- 4:47 CTR $10,000 cash rule and aggregating same-day deposits
- 6:00 Structuring as a standalone federal crime
- 7:17 SAR vs CTR side-by-side showdown
- 8:20 Rapid-fire exam recap
What this video covers
- Why a registered representative (RR) escalates to the firm's anti-money laundering compliance officer (AMLCO) instead of contacting the Financial Crimes Enforcement Network (FinCEN) directly
- The $5,000 SAR threshold, the four suspicion triggers, and the 30-day (up to 60-day) filing deadline
- The absolute no-tipping rule and the 5-year SAR recordkeeping requirement
- The $10,000 CTR threshold for cash transactions and why suspicion is irrelevant to the trigger
- How aggregate same-day cash deposits across one customer combine to cross the CTR threshold
- Why structuring is a federal crime on its own, even when the underlying funds are legitimate
- The side-by-side SAR vs CTR comparison: threshold, trigger, customer notification, and filing deadline
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