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December 13, 2006
Amended Interpretive Notice to Compliance Rule 2-9: FCM and IB Anti-Money Laundering Programs
NFA's Board of Directors recently amended NFA's Interpretive Notice to Compliance Rule 2-9: FCM and IB Anti-Money Laundering Programs to update the notice to include all FCM and IB anti-money laundering requirements that have been adopted by FinCEN and/or the CFTC since NFA first issued the interpretive notice in April 2002.
The amendments to the interpretive notice do not expand FCM/IB responsibilities, but rather consolidate the current requirements into one document. FCMs and IBs, however, must continue to keep current with federal rulemakings as they are adopted.
The revisions to the interpretive notice include the following:
FCM and IB Members should review their AML Compliance Program to ensure that it is in full compliance with these requirements. In recent months, NFA's Business Conduct Committee has issued a number of Complaints involving violations of these requirements. The most common violations involve an inadequate Customer Identification Program, failing to adopt adequate procedures for suspicious activity monitoring and reporting, failing to complete the annual independent review of the program and failing to provide annual training to appropriate employees.
If you have any questions on the amendments to the Interpretive Notice, please do not hesitate to contact Sharon Pendleton, Director, Compliance at firstname.lastname@example.org or Carol Wooding, Assistant General Counsel, at email@example.com.