AML Compliance: Rapid Fire

What this video covers

• Placement, layering, and integration: the three stages of money laundering and why structuring is a placement technique, not layering
• How the Suspicious Activity Report (SAR) triggers at suspicious activity of $5,000 or more, and why the Currency Transaction Report (CTR) triggers automatically at cash over $10,000 on a single business day
• The chain of command for reporting: the registered representative reports to the Anti-Money Laundering Compliance Officer (AMLCO), who investigates and files with the Financial Crimes Enforcement Network (FinCEN)
• Why tipping off is strictly prohibited: the firm can never tell a customer that a SAR was filed
• The SAR deadlines: 30 calendar days with an identified suspect, 60 calendar days without one, and why 10 days is the Office of Foreign Assets Control (OFAC) trap
• FinCEN versus OFAC: both are Treasury bureaus, but FinCEN receives SARs and CTRs while OFAC administers sanctions and the Specially Designated Nationals (SDN) List
• The five AML program pillars plus Customer Identification Program (CIP), and why independent testing can be internal staff as long as they have no role in running the program