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March 31, 2022
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NFA orders New York, N.Y. swap dealer Goldman Sachs & Co., LLC to pay a $2,500,000 fine
March 31, Chicago—NFA has ordered New York, N.Y. swap dealer Member Goldman Sachs & Co., LLC (Goldman) to pay a $2,500,000 fine.
The Decision, issued by NFA's Business Conduct Committee (BCC), is based on a Complaint issued by the BCC and a settlement offer submitted by Goldman, in which it neither admitted nor denied the allegations. The Complaint alleged that Goldman did not collect or post variation margin (VM) on uncleared swaps with counterparties that were covered by the CFTC VM regulations. The Complaint also alleged that Goldman did not implement policies and procedures reasonably designed to ensure compliance with its pre-trade mid-market mark (PTMM) obligations and did not provide PTMM to uncleared swaps counterparties when required. Additionally, the Complaint alleged that Goldman failed to promptly submit accurate and complete reports, documents and supplemental information to NFA, did not diligently supervise all activities relating to its business and did not monitor the firm's compliance with certain external business conduct standards policies and procedures. In its Decision, the BCC found that Goldman violated NFA Compliance Rule 2-49(a) and 2-49(b).