2.2.1.5.3. 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 (for example, cashier’s checks) 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 client 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.
Suspicious Activity Reports must be filled out whenever a client makes a transaction in excess of $5,000 and the broker-dealer knows or suspects foul play, specifically if the transaction seems to have:
• Arisen from illegal activity or attempted to disguise funds or assets derived from illegal activity
• Attempted to avoid reportin