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Since NFA adopted its Interpretive Notice to NFA Compliance Rule 2-9: FCM and IB Anti-Money Laundering Program in early 2002, there have been a number of additional anti-money laundering requirements imposed by FinCEN and the CFTC on NFA FCM and IB Members. NFA has amended its Notice adopted in April 2002 to include all requirements currently imposed on FCMs and IBs.
The revised interpretive notice includes changes in the following areas.
- The addition of Customer Identification Program requirements and guidance issued on these requirements;
- The deletion of the Customer Identification and Verification section because it was replaced with the Customer Identification Program requirements;
- The addition of Suspicious Activity Reporting requirements and guidance that was issued regarding these requirements;
- The addition of 314(a) Information Request requirements and guidance that FCMs are required to comply with. This section includes the requirement that FCMs designate a point of contact for these requests and that any changes to the point of contact information be immediately reported to NFA;
- The addition of the Private Banking and Correspondent Account requirements and the guidance that was issued regarding these requirements;
- A revision to the independent audit function requirement that would permit FCMs and IBs that do only proprietary business or that are inactive to conduct their independent audit on a 2-year, rather than 1-year, cycle. This change is consistent with a similar NASD amendment made earlier this year; and
- A relocation of the Allocation of Compliance Program Responsibilities section. This information was previously included in the customer identification and verification section, however, the requirements of this section apply to other program requirements and NFA feels it is appropriate to set it out in a separate section.