On an annual basis, Independent Introducing Brokers and Futures Commission Merchants are required to have an independent review of their AML policies and procedures.  This is required per NFA from registration and beyond.  Falling outside of the 12 month requirement may cause compliance deficiencies and citing should NFA conduct an onsite audit.

An AML program is a set of procedures designed to guard against someone using the firm to facilitate money laundering or terrorist financing.  The main components that must be included are:

• internal policies, procedures and controls reasonably designed to assure compliance with the Bank Secrecy Act and implementing regulations;
• appointment of a designated compliance officer to oversee the program’s day-to-day operations;
• a customer identification program (CIP);
• an ongoing training program; and
• an independent audit.

For standards of an adequate AML program and additional guidance please visit the NFA website here.

Our firm can perform your annual AML Audit requirements.  For more information and to make sure you are in compliance, please call Mike Coglianese at 630-351-8942 or email Mike@cogcpa.com.