On July 22, the Commodity Futures Trading Commission, in conjunction with the Financial Crimes Enforcement Network (FinCEN), issued interpretative guidance to introducing brokers in commodities (IBs) that do not introduce customers to a futures commission merchant (FCM) that carries their customers’ accounts.

The interpretative guidance clarifies that an IB that does not introduce customers to an FCM is not required to implement the customer identification program (31 CFR Section 1026.220) or beneficial owner (31 CFR Section 1010.230) rules.

CFTC Letter No. 19-18 is available here.