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Notice I-04-23

December 06, 2004

NFA develops questionnaires for writing anti-money laundering, business continuity, ethics training and privacy policies

National Futures Association has published a set of questionnaires to assist Member firms in adopting written policies with respect to anti-money laundering requirements, business continuity/disaster recovery planning, privacy policies and ethics training. Developed as part of our ongoing efforts to help our Members meet their regulatory responsibilities as efficiently as possible, the questionnaires are available on NFA's Web site at http://www.nfa.futures.org/compliance/grr99.asp or http://www.nfa.futures.org/compliance/selfexam.asp.

Incorporating suggestions from Member firms, we have written the questionnaires to focus on the areas where firms experience the most problems during our examinations. We recognize that many of these requirements are fairly new to the futures industry and several of the rules, regulations and laws that govern the policies are complex. However, it is essential that you develop effective policies that allow your firm to be prepared in the event of a business disruption, to be proactive in detecting money laundering and suspicious activity, to provide customers with privacy notices and to ensure that all of your employees periodically complete ethics training.

Each Member firm must adopt written policies tailored to its operations regarding these areas. You should maintain your written procedures on file. Equally as important, you should communicate your policies to your employees and implement your procedures once they are developed.

Our Compliance Department staff is available to answer any questions you may have regarding these procedures. Please do not hesitate to contact NFA at (800) 621-3570.

NFA is the premier independent provider of efficient and innovative regulatory programs that safeguard the integrity of the futures markets.
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