March 24, 2022

NFA Directs Members to FinCEN Alert on AML Duties in Light of Russia Sanctions

NFA directed member firms to a recent FinCEN Alert stressing the AML obligations of futures commission merchants and introducing brokers in the wake of ongoing Russia-related sanctions. FinCEN stressed financial institutions' duty to identify and swiftly report any suspicious transactions that involve "real estate, luxury goods, and other high-value assets" of sanctioned Russian elites and their proxies. FCMs and IBs were alerted to their (i) customer due diligence requirements regarding the "identification of a legal entity owned or controlled by a foreign politically exposed person" and (ii) general due diligence requirements for correspondent accounts.

This guidance followed on the heels of a FinCEN Alert from March 7, 2022, through which financial institutions were reminded to be vigilant in their Bank Secrecy Act reporting amidst expansive Russia-related sanctions due to the invasion of Ukraine.

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