AML, Privacy & Cybersecurity Essentials
Key AML thresholds, reports, and privacy rules tested on the SIE.
Keyboard Shortcuts
💡 Pro tip: Use keyboard shortcuts for faster studying!
Study Smart Tips for AML, Privacy & Cybersecurity Essentials
Master these concepts using proven study techniques that actually work:
Active Recall
Test yourself before flipping each card to strengthen memory retention
Spaced Repetition
Review difficult cards more frequently than easy ones
Multiple Sessions
Break study time into shorter, focused sessions
Explain Aloud
Verbalize answers to reinforce understanding
Questions Covered in This Set
11 cards to master
Three stages of money laundering
Placement (cash enters the system), Layering (transactions obscure the trail), Integration (money reappears as legitimate wealth).
What is the Bank Secrecy Act (1970) and who administers it?
The foundational AML statute, administered by FinCEN, a bureau of the U.S. Treasury (not the SEC or FINRA).
CTR: trigger and deadline
Currency Transaction Report (FinCEN Form 112) — cash transactions exceeding $10,000 in one business day by/for the same person; filed within 15 days.
SAR: trigger and deadline
Suspicious Activity Report (Form 111) — suspicious transactions of $5,000 or more; filed within 30 days (60 if no suspect identified).
Can a firm tell a customer a SAR was filed?
No — 'tipping off' is prohibited. SAR records are kept 5 years, and firms have safe harbor from civil liability for good-faith filings.
What is structuring?
Breaking a large cash transaction into smaller amounts to evade the $10,000 CTR threshold; it is a federal crime, and assisting a customer is a serious violation.
Five required elements of an AML program under FINRA Rule 3310
Written policies, annual independent testing, a designated AML Compliance Officer, ongoing training, and risk-based customer due diligence (including beneficial owners).
What does OFAC do?
A Treasury office that maintains the SDN list; firms must screen customers and block/freeze assets of sanctioned persons — sanctions compliance, not suspicious-activity reporting.
Does a $50,000 check or wire trigger a CTR?
No — CTRs apply only to currency (cash). A large check or wire could still trigger a SAR if suspicious.
CMIR vs. FBAR
CMIR: physical transport of more than $10,000 in cash/monetary instruments into or out of the U.S., filed at time of transport. FBAR: foreign financial accounts aggregating over $10,000, filed annually.
How does terrorist financing differ from money laundering?
It often works in reverse — small amounts of legitimate money funneled to illegitimate purposes; the USA PATRIOT Act (2001) expanded AML rules to address it.
