NFA Issues Interpretive Notice on Compliance Rule 2-9: FCM and IB Anti-Money Laundering Program

The NFA issued an Interpretive Notice regarding NFA Compliance Rule 2-9 ("Supervision") and its requirement for all financial institutions, including futures commission merchants ("FCMs") and IBs, to establish anti-money laundering ("AML") programs. The purpose of the Interpretive Notice is to highlight the minimum standards of AML programs and provide NFA Member FCMs and IBs with additional guidance on satisfying the requirements of NFA Compliance Rule 2-9(c). Compliance Rule 2-9(c) states that AML programs must, at a minimum, include internal policies, procedures, and controls; a designated compliance officer to oversee day-to-day operations of the program; an ongoing training program for employees; and an independent audit function to test the program.

See: NFA Interpretive Notice 9045.See generally: The Cadwalader Cabinet Guide to AML.