Identifying and Escalating Suspicious Activity
Chapters in this video
- 0:00 Carla's $5,000 ferret wire and the escalation chain
- 1:42 The rep reports, AMLCO files: avoiding the FinCEN trap
- 2:24 SAR threshold, triggers, and voluntary filings
- 2:59 30-day and 60-day SAR deadlines
- 3:55 The absolute no-tipping rule
- 4:26 Carla's cash bag and the $10,000 CTR trigger
- 5:23 Structuring as a standalone federal crime
- 6:03 CTR filing deadline and 5-year record retention
- 6:54 SAR vs CTR side-by-side comparison
- 7:33 Rapid-fire exam recap
What this video covers
- The precise escalation chain: registered representative detects, then reports to the anti-money laundering compliance officer (AMLCO), then the firm files with FinCEN, and why reps never contact FinCEN directly
- The $5,000 threshold that triggers a Suspicious Activity Report (SAR), the four specific types of suspicion that qualify, and why a firm may voluntarily file below the threshold
- The 30-day SAR filing deadline when a suspect is identified, the 60-day maximum when no suspect is identified, and the immediate telephone notification requirement for terrorist financing or ongoing money laundering
- The absolute no-tipping rule: who you cannot tell about a SAR filing, and the limited parties to whom a SAR may legally be disclosed
- The $10,000 cash threshold that automatically triggers a Currency Transaction Report (CTR), why no suspicion is required, and how multiple same-day cash transactions aggregate
- Why structuring, intentionally breaking cash transactions to stay below $10,000, is a standalone federal crime regardless of the funds' origin
- The 15-day CTR filing deadline and the 5-year record retention rule that applies to both SARs and CTRs
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