Co-authored by Kenneth M. Rosenzweig and Christian B. Hennion
National Futures Association (NFA) has launched a new online system to assist futures commission merchants (FCMs) and introducing brokers (IBs) in developing anti-money laundering (AML) programs. The system is designed to help users identify the minimum required components of an AML program and to provide additional guidance and information on the various components of the program, including example provisions. FCMs and IBs are not required to use the system in designing their AML program, and use of the system does not provide users with a “safe harbor” from applicable AML requirements under NFA rules or federal law. NFA further cautions that the system is only intended to provide an outline for an AML program, which may need to be further tailored to the specific risks of a firm’s business.
The NFA notice to members announcing the launch of the new system, as well as instructions for accessing the system, is available here.