United States
Hong KongBSA, AML and suspicious activity reports
A suspicious activity report must be filed within 30 calendar days of initial detection. A currency transaction report is required for cash over 10,000 dollars in a day. Disclosing a SAR to its subject is prohibited.
The Bank Secrecy Act framework reaches residential mortgage lenders and originators, and the exam treats it as a set of hard rules with hard numbers.
The two reports
| Report | Trigger | Deadline |
|---|---|---|
| Suspicious activity report | Known or suspected criminal activity or suspicious transaction | 30 calendar days from initial detection |
| Currency transaction report | Cash transactions over 10,000 dollars in a day | As prescribed |
Learn both numbers. They are among the most reliably asked figures in this part of the syllabus.
The confidentiality rule
You may not tell the subject of a suspicious activity report that one has been filed, or that one is being considered.
Not a hint, not a warning, not a suggestion they might want to withdraw the application. The prohibition is absolute.
A scenario will describe an originator who suspects fraud and asks what they should do. Any option involving telling the borrower is wrong, however sympathetically it is phrased.
The program requirements
An institution must have an anti-money laundering program with four pillars: internal policies and controls, a designated compliance officer, ongoing training, and independent testing.
Four. The count is asked.
Structuring
Breaking a large cash transaction into smaller ones to avoid a reporting threshold is itself an offense, regardless of whether the underlying money is legitimate.
A borrower depositing 9,500 dollars on three consecutive days has structured, and that is reportable on its own.
The Red Flags Rule
Separate from anti-money laundering but often examined alongside it. It requires a written identity theft prevention program to detect and respond to indicators of identity theft.
Common questions
How long do you have to file a suspicious activity report?
30 calendar days from initial detection.
When is a currency transaction report required?
For cash transactions over 10,000 dollars in a day.
Can you tell someone a SAR was filed about them?
No. Disclosure to the subject is prohibited absolutely.
What are the four pillars of an AML program?
Internal policies and controls, a designated compliance officer, ongoing training, and independent testing.
What is structuring?
Breaking transactions into smaller amounts to avoid a reporting threshold. It is an offense in itself.