Anti-Money Laundering Compliance Program
FINRA member firms are required to establish in writing and to implement policies, procedures, and internal controls designed to achieve compliance with the following reporting and recordkeeping requirements of the Bank Secrecy Act:
• To record cash purchases of negotiable instruments between $3,000 and $10,000 in a Monetary Instrument Log (MIL), and to maintain these records for a minimum of five years.
• To report to the IRS any cash transactions in a single day exceeding $10,000, whether conducted in one transaction or several smaller ones, using FinCEN’s Currency Transaction Report (CTR).
» Multiple currency transactions in excess of $10,000 may be reported as a single transaction if they are made by the same person or on the same person’s behalf. Similarly, multiple businesses that share a common owner may be treated as a single business entity if evidence obtained in the ordinary course of business suggests that the businesses are not operating independently.
» Types of currency transactions subject to the CTR reporting requirement include deposits and withdrawals, denomination exchanges, loan payments, ATM transactions, purchases of certificates of deposit, and funds transfers paid for in currency. CTRs must be filed with FinCEN within 15 calendar days after the date of the transaction.
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