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Commentary by Bob Zwirb

Citigroup Global Markets, Inc., a registered futures commission merchant and provisionally registered swap dealer, agreed to pay a $25 million civil monetary penalty to settle CFTC charges of spoofing and related supervisory failures.

The NFA issued an updated version of its Self-Examination Questionnaire that NFA member firms, including FCMs, IBs, CPOs and CTAs, are required to complete on an annual basis. The Self-Examination Questionnaire includes a general questionnaire that must be completed by all NFA member firms and supplemental questionnaires tailored to the business activities of the various categories of NFA members (FCMs, FDMs, IBs, CPOs and CTAs). The Self-Examination Questionnaire is intended to assist NFA member firms in recognizing potential problem areas, and to alert firms to procedures that need to be

NFA submitted a proposed rule change to the CFTC regarding the proposed amendments to the Interpretive Notice to NFA Compliance Rule 2-9: FCM and IB anti-money laundering program. The compliance rule applies to notice-registered broker-dealer and IB transactions in securities futures products. The NFA made the following rule clarifications: (i) for omnibus accounts opened by an intermediary, AML is of the intermediary but not of the underlying holders; (ii) for the account of a pool, AML is of the pool but not of investors in the pool; and (iii) in a give-up arrangement, it's the clearing