Per NFA Compliance Rule 2-9(c), all FCMs and IBs are required to implement and maintain an Anti-Money Laundering Program to remain in compliance with the Bank Secrecy Act.  Recently, The CFTC put forth guidance to grant relief to certain voice Introducing Brokers.  These are Introducing Brokers that do not introduce an account to an FCM and therefore do not have customers.  Voice Introducing Brokers are no longer obligated to establish and implement the Customer Identification Program (CIP) and Beneficial Ownership (BO) requirements.

However, voice Introducing Brokers are still required to conduct suspicious activity reviews and comply with other applicable NFA requirements.

The complete detail of the CFTC Guidance can be found here.

If you need to discuss your AML requirements please call Mike Coglianese at 630-461-5841 or email Mike@cogcpa.com.