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NFA issued separate Complaints charging two NFA-registered introducing brokers with AML program violations and recordkeeping and capital minimum failures. NFA charged DMFiala LTD ("DMF") with failing to fully implement the firm's anti-money laundering ("AML") program, thereby violating NFA Compliance Rule 2-9(c). NFA found that DMF was required to have its 2013 annual audit of its AML program completed by May 31, 2013, but did not have the audit completed until August 2013. Additionally, NFA found that DMF's 2007 audit was late by approximately 12 months, and that DMF was over four months late