NFA proposed an amendment to an interpretive notice on AML compliance procedures to clarify the obligations of certain introducing brokers under a written Customer Identification Program and Beneficial Ownership regulations.
In a joint statement, the CFTC, FinCEN and the SEC reminded those engaged in digital asset transactions to comply with anti-money laundering and countering the financing of terrorism obligations under the Bank Secrecy Act.
The CFTC Division of Swap Dealer and Intermediary Oversight clarified the circumstances in which Customer Identification Program and Beneficial Ownership regulations under the Bank Secrecy Act do not apply to "voice" brokers.
On Monday, March 25, 2019, Cadwalader partners Jodi Avergun and Steven Lofchie will host a SIFMA Lunch & Learn demonstration of how technology can be leveraged to keep pace with regulatory uncertainty.
Recently adopted guidance requires NFA commodity pool operators to (i) implement an internal controls framework designed to protect customer funds, and (ii) provide assurance that the books and records of commodity pools are accurate.
The National Futures Association proposed an Interpretive Notice that requires commodity pool operators to adopt internal control systems to deter fraud, protect customer funds and pool assets, and assure the accuracy of records.
The SEC and CFTC filed separate charges against the operator of an online trading platform and its CEO for violating several federal securities and commodities exchange laws in connection with swaps and security-based swaps funded with bitcoins.
The National Futures Association advised futures commission merchants and introducing brokers to ensure that their anti-money laundering programs comply with OFAC requirements on virtual currency transactions.
The NFA urged futures commission merchants and independent brokers to revise their anti-money laundering programs to reflect the most current information on jurisdictions with strategic deficiencies identified by the Financial Action Task Force.
The New York Department of Financial Services requested comments on proposed revisions to cybersecurity rules that apply to a wide range of insurance, banking and financial services companies under its supervision.
JP Morgan Securities LLC, a registered futures commission merchant and swap dealer, agreed to pay a civil monetary penalty to settle CFTC charges that it failed to maintain adequate systems for reconciling exchange and clearing fees for trading of Chicago Mercantile Exchange products.
Cadwalader attorneys reviewed FinCEN's expansion of the number of locales in which it will use Geographic Targeting Orders to temporarily require U.S. title insurance companies to identify the "beneficial owners" behind the legal entities used to make "all-cash" purchases of high-end residential real estate.