8.2.1.2. 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 amended 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). The CTR must be filed within 15 calendar days.
•To file a Suspicious Activity Report (SAR) on any customer who appears to be avoiding Bank Secrecy Act reporting requirements or is behaving in a way that suggests money laundering or some other illegal activity. The SAR must be filed within 30 calendar days.
Suspicious Activity Reports must be filled out whenever a customer makes a transaction in excess of $5,000 and the b