All futures commission merchants (FCM) and introducing brokers (IB) are required to have an anti-money laundering (AML) compliance program in place pursuant to the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (Title III).
An AML program is a set of procedures designed to guard against someone using the firm to facilitate money laundering or terrorist financing. The minimum requirements of a program are:
- internal policies, procedures and controls reasonably designed to achieve compliance with the Bank Secrecy Act and implementing regulations;
- appointment of a designated compliance officer to oversee the program's day-to-day operations;
- an ongoing training program;
- an independent audit; and
- appropriate risk-based procedures for conducting customer due diligence including, but not limited to:
- understanding the nature and the purpose of developing a customer risk profile; and
- conducting ongoing monitoring to detect and report suspicious transactions and on a risk basis to maintain and update customer information including identifying and verifying beneficial owners.
NFA Interpretive Notice to Compliance Rule 2-9: FCM and IB Anti-Money Laundering Program highlights the minimum standards of an adequate AML program and provides Members with additional guidance on satisfying NFA's requirements. NFA's Anti-Money Laundering (AML) Procedures System is designed to assist Members in developing an adequate written compliance program by identifying the minimum components of the program and providing guidance and information on the components.