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Anti-Money Laundering

The International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (Title III), which was signed into law on October 26, 2001, imposes significant anti-money laundering requirements on all "financial institutions," as defined under the Bank Secrecy Act ("BSA"), including FCMs and IBs. CPOs and CTAs are also defined as "financial institutions" under the BSA; however, the Secretary of Treasury has deferred applications of these requirements for an unspecified period.

Since April 24, 2002, all NFA Member FCMs and IBs have been required to have an anti-money laundering (AML) compliance program in place. NFA has provided ongoing guidance to our Members as they developed and implemented their programs. The table below provides links to the rules and regulations governing AML compliance as well as resources and other tools to assist Members in meeting their AML requirements.

Questions concerning a Member's AML program can be directed to Valerie Kretschmer, Manager, at (312) 781-1290, vkretschmer@nfa.futures.org or Sharon Pendleton, Director at (312) 781-1401, spendleton@nfa.futures.org.

Rules/Regulations	Resources
Compliance Rule 2-9. Supervision Interpretive Notice NFA Compliance Rule 2-9: FCM and IB Anti-Money Laundering Program Customer Identification Program Requirements Suspicious Activity Reporting Requirements 314 Information Sharing Requirements Private Banking Account Requirements Department of Treasury Finalizes Rule under Section 311 Against Banco Delta Asia	Web-based Training Self-Examination Checklist For FCMs Self-Examination Checklist For IBs Anti-Money Laundering Questionnaire for FCMs and IBs Questions and Answers Regarding the Customer Identification Program Rule for Futures Commission Merchants and Introducing Brokers SAR-SF Form and Instructions 314(b) Certification Guidance on Sharing of Suspicious Activity Reports by Securities Broker Dealers, FCMs and IBs Request to Treat Certain CTAs as Subject to AML Program Rule for Purposes of CIP Reliance Provision
Notices to Members	Useful Websites
I-10-08: FinCEN adds Enhancements to its BSA E-Filing System I-07-34: FinCEN Issues Final Rule Relating to Enhanced Due Diligence Requirements for Correspondent Accounts Maintained by Certain Foreign Banks I-07-26: FinCEN Issues Guidance Regarding Suspicious Activity Report Supporting Documentation and Requests by Law Enforcement for Financial Institutions to Maintain an Account I-07-20: CFTC and FinCEN Issue Guidance on CIP Requirements with Respect to Give-up Arrangements I-06-20: Amended Interpretive Notice to Compliance Rule 2-9: FCM and IB Anti-Money Laundering Programs I-06-14: USA Patriot Act Special Due Diligence Program For Certain Foreign Accounts I-05-02: USA PATRIOT Act Section 314(a) Web-based Delivery and Reporting System I-04-23: NFA develops questionnaires for writing anti-money laundering, business continuity, ethics training and privacy policies I-04-21: USA Patriot Act 314(a) Information Requests I-04-03: Department of Treasury Issues Final Rule Requiring FCMs and IBs to File Suspicious Activity Reports I-03-18: USA PATRIOT Act Section 314(a) Information Requests	Financial Crimes Enforcement Network CFTC's AML Webpage Office of Foreign Assets Control Financial Action Task Force

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