Anti-Money Laundering

The Bank Secrecy Act (BSA), as amended by the Patriot Act, is designed to prevent, detect, and prosecute international money laundering and the financing of terrorism. The BSA and related regulations require futures commission merchants (FCMs) and introducing brokers (IBs) to establish anti-money laundering (AML) programs, report suspicious activity, verify the identity of customers and apply enhanced due diligence to certain types of accounts involving foreign persons. In the future, it is possible that commodity pool operators (CPOs), commodity trading advisors (CTAs), swap dealers (SDs), major swap participants (MSPs), and other CFTC registrants may be required to comply with anti-money laundering regulations. However, it should be noted that CPOs, CTAs, SDs, MSPs, and RFEDs have certain AML-related reporting obligations under the existing currency transactions reporting regulations, foreign bank and financial account reporting regulations and international transportation of currency or monetary instrument regulations. They also have obligations under the sanctions programs that target jurisdictions or individuals and further U.S. foreign and domestic policies.

Below is a general outline of important AML topics with links to general information and resources. In addition, links to the AML webpages for the National Futures Association (NFA), Financial Crimes Enforcement Network (FinCEN), Office of Foreign Assets and Control (OFAC), FINRA, and SEC are included in the right margin.

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