A customer deposits an $8,000 cashier's check in their account. Later the same day, they deposit a $2,500 money order. Which of the following actions, if any, must the firm take in response to this activity?
The correct answer is A (No filing required) based on the facts provided. A Currency Transaction Report (CTR) is generally triggered by currency transactions (cash) over the applicable threshold within a single business day. In this scenario, the customer deposited a cashier's check and a money order, which are monetary instruments, not ''currency'' (cash). Therefore, even though the combined amount is $10,500, the deposits described are not cash deposits, so this does not automatically require a CTR.
A Suspicious Activity Report (SAR) is required when activity is suspicious and meets reporting criteria---such as transactions that appear designed to evade reporting requirements, have no apparent lawful purpose, involve potential money laundering, or otherwise raise red flags. Here, the amounts and instruments alone---$8,000 cashier's check and $2,500 money order deposited the same day---do not necessarily indicate suspicious activity. Without additional facts (e.g., patterns of structuring, inconsistent customer profile, unusual source of funds, evasive behavior, or other AML red flags), the firm is not required to file a SAR solely on this activity.
Form W-9 is used to request a taxpayer identification number and certification for certain tax-reporting purposes, but it is not a standard ''required filing'' triggered by these deposits as described.
The SIE tests the ability to distinguish between currency-based reporting (CTR) and suspicion-based reporting (SAR), and to recognize that not every large or same-day deposit is automatically reportable without meeting the specific rule trigger.
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