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What is an Anti-Money Laundering Program?

An anti-money laundering (AML) program is a set of procedures designed to guard against someone using the firm to facilitate money laundering or terrorist financing. The main components that must be included are: 1) internal policies, procedures, and controls reasonably designed to assure compliance with the Bank Secrecy Act and implementing regulations; 2) appointment of a designated compliance officer to oversee the program's day-to-day operations; 3) an ongoing training program; and 4) an independent audit.  See NFA Compliance Rule 2-9(c) and the Interpretive Notice 9045 for more details.

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