Customer Screening and Documentation: Rapid Fire
Chapters in this video
- 0:00 The four CIP items and the PO box trap
- 2:28 OFAC hits: stop, escalate, stay silent
- 3:10 CTR vs SAR: cash thresholds and filing deadlines
- 5:47 Limited POA, full POA, and the death of the principal
- 6:37 Full discretion: three requirements vs time-and-price discretion
- 7:28 Reg S-P opt-outs, corporate insiders, and employee-account consent
- 8:18 Rapid-fire exam recap
What this video covers
- The four exact CIP items (name, date of birth, physical address, identification number) and why a post office (PO) box alone fails while a temporary street address passes
- How Customer Identification Program (CIP) is a one-time identity check at or before account opening, while Know Your Customer (KYC) is an ongoing duty to maintain essential facts
- The Office of Foreign Assets Control (OFAC) hit protocol: stop processing, escalate to compliance immediately, and never tip off the customer
- Why the $10,000 cash threshold triggers a Currency Transaction Report (CTR) with no suspicion needed, while the $5,000 threshold plus suspicion triggers a Suspicious Activity Report (SAR) filed by compliance, never the rep
- How structuring cash deposits to evade the $10,000 CTR threshold is itself a federal crime, independent of the underlying activity
- The three requirements for full discretion (prior written customer authorization, written firm acceptance by a principal, and discretionary marking on every order ticket) versus time-and-price discretion, which expires at the close of the same business day with no written authorization required
- Why all powers of attorney, including durable POAs, terminate instantly at the principal's death; and the difference between limited POA (trade only) and full POA (trade plus withdraw)
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