As you know, 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 recognizes that this has been a significant endeavor for our Members and we have provided ongoing guidance to our Members as they developed and implemented their programs. NFA also regularly gathers feedback from our Members in order to assist them in meeting their regulatory responsibilities. As part of this feedback process, a number of Members have expressed concern that given the breadth of the AML requirements, some of their AML responsibilities may be inadvertently overlooked. As we approach the one-year anniversary of the AML program requirement, NFA recommends that FCM and IB Members review their AML compliance program to ensure that it covers all aspects of NFA Compliance Rule 2-9(c) and Interpretive Notice NFA Compliance Rule 2-9: FCM and IB Anti-Money Laundering Compliance Program. In particular, Members are reminded of the following annual requirements that must be implemented by April 24, 2003:

• FCM and IB Members must conduct annual testing of their AML compliance program. This testing can be done by a firm's personnel (such as an internal audit staff) who are independent of the personnel working in areas that are exposed to potential money laundering risks or by hiring an outside party with experience with this type of auditing. The results of this review should be documented and reported to the firm's senior management or an internal audit committee or department.

• FCM and IB Members must provide ongoing education and training for all appropriate personnel. At a minimum, a firm should provide annual training on the firm's policies and procedure, the relevant federal laws and NFA AML requirements. Firms should also maintain records to evidence their compliance with this requirement.

NFA also reminds Members that there are a number of pending AML proposals that, when finalized, will require modifications to existing AML programs. Therefore, Members must keep abreast of changes and regularly review their AML program to ensure that it meets the requirements of any subsequent changes to federal law and/or NFA's requirements. Members are encouraged to contact NFA with questions regarding their AML responsibilities and consult NFA's Web site at www.nfa.futures.org. Members can contact Sharon Pendleton (spendleton@nfa.futures.org) at (312) 658-6540, Darlene Chappell (dchappell@nfa.futures.org) at (312) 658-6553 or Carla Colone (ccolone@nfa.futures.org) at (212) 513-6028.