Anti-Money-Laundering Compliance Summary

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1 Anti-Money-Laundering Compliance Summary It is imperative that futures industry professionals, who may be susceptible to money-laundering schemes, be cognizant of their responsibilities and follow proper procedures to avert illegal activity. NFA Compliance Rule 2-9 (c) and its related Interpretive Notice establish certain standards and requirements to thwart, detect, and report attempted and actual money laundering. Three areas are most relevant for the prevention of money laundering: customer identification programs, monitoring accounts for suspicious activity, and reporting of suspicious activity, and are further discussed below. Customer Identification Program (CIP) To help the government in the fight against terrorism and money-laundering activities, federal law requires financial institutions to obtain, verify and record information that identifies each person who opens an account. The following highlights the principal aspects of a futures industry customer identification program. Every FCM and IB has an obligation to establish and implement an independent customer identification and verification program. The Know Your Customer requirement of NFA Rule 2-9 (c), dealing with anti-moneylaundering (AML) programs differs from the Know Your Customer requirement of NFA Rule 2-30, pertaining to account openings. 1. NFA Rule 2-9 (c) applies to all accounts, and its purpose is to ascertain: who is the customer; what is the customer s business; and what is the intended purpose of the customer s transactions. 2. NFA Rule 2-30 applies only to individual accounts and has as its objective sufficient knowledge of the customer to assure adequate risk disclosure. The minimum information that must be obtained and appropriately maintained to accomplish the objectives of a firm s AML customer identification program is: 1. For all accounts, the customer s name and address; 2. For accounts of natural persons, the customer s date of birth; 3. For accounts of non-natural persons, the customer s principal place of business; 4. For accounts of a US person, the customer s social security number or taxpayer identification number (TIN); 5. For a natural person who is not a U.S. person, the customer s tax identification number, current passport number and country of issuance, alien identification card number, or the number and country of issuance of any other valid government identification document that bears a photograph or other biometric identifier. Other documents required for a client to open an account also may be useful in identifying the client such as driver s license or other identifying documents. A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, 1

2 certified articles of incorporation, government-issued business license, a partnership agreement or a trust agreement. CIP requirements do not apply to futures accounts that existed as of October 1, 2003 and accounts obtained by acquisition of another firm provided that the firm where the account currently resides has reason to believe it knows the true identity of the customer. Certain customer behavior during the account opening process or subsequently may signal the need for further investigation by the firm. Examples include customers: 1. Who are excessively secretive about their identity, type of business or source of assets; 2. Who are disinterested in the costs and/or risks of futures trading; 3. Who appear to be acting as agents for other entities or individuals and who are evasive about the agency relationship and/or the other entities or individuals; 4. Whose appearance or response to questions is inconsistent with the customers documents or previous statements; 5. Who have corporate accounts and lack knowledge of their entities businesses or industries; 6. Who are from jurisdictions identified as problem areas for money laundering, terrorist financing, narcotics production, or bank secrecy. For prospective accounts from such jurisdictions a firm should determine what, if any, additional due diligence is necessary in deciding whether to accept the account and, if accepted, what, if any, additional monitoring is required. Firms must have procedures to identify potentially high-risk accounts that, for whatever reason, are judged to be particularly vulnerable to money laundering. These procedures must provide for the enhanced verification of customer identity as well as continuing monitoring of such accounts if they are accepted. For high-risk customers who are not individuals, firms also must obtain identifying information about those persons who have authority or control over the accounts. FCMs and IBs should monitor FinCEN's website at for information on foreign jurisdictions, institutions, classes of transactions, or types of accounts that have been designated as a primary money-laundering concern, and any special measures that have been imposed. Because certain types of entities and those from certain geographic locations are especially vulnerable to money laundering, firms should consult lists of high-risk countries, including non-cooperative jurisdictions and restricted countries subject to sanction by the Office of Foreign Assets and Control (OFAC). Firms also must check OFAC s list of Specially Designated Nationals and Blocked Persons (SDN list) that contains names of suspected or known terrorists or terrorist organizations and notify OFAC if an account applicant s name appears on the list. The OFAC and information on how to handle matches can be found at The Financial Action Task Force's (FATF) serves as the global standard setting body for antimoney laundering and combating the financing of terrorism. FATF identifies jurisdictions that have strategic deficiencies and works with them to address deficiencies that pose a risk to the 2

3 financial system. Because certain types of entities, individuals and those from certain geographic locations are especially vulnerable to money laundering, firms should regularly consult the FATF's public statements/advisories at as changes may affect U.S. financial institutions obligations and risk-based approaches with respect to relevant jurisdictions. If the customer is from one of the jurisdictions countries/territories identified as having Anti- Money-Laundering and Counter-Terrorism Financing Act (AML/CFT) deficiencies on the list of Non-Cooperative Countries and Territories (NCCT list), the FCM or IB should determine what, if any additional due diligence is necessary in deciding whether to open the account, and if the account is accepted, what, if any, additional monitoring of the account activity is appropriate. Verification of a customer s identity must occur within a reasonable period of time before or after an account is accepted. Such verification may include use of information from consumer reporting agencies, public databases and other sources. There may be situations where an FCM or IB cannot form a reasonable belief that it knows the true identity of the customer and the firm must have procedures in place to address how to handle such occurrences. At a minimum, these procedures should address: (1) when an account should not be opened; (2) the terms under which a customer may conduct transactions while the FCM or IB attempts to verify the customer's identity; (3) when an account should be closed after attempts to verify a customer's identity have failed; and (4) when the FCM or IB should file a Suspicious Activity Report (SAR) in accordance with applicable laws and regulations. Monitoring Accounts to Detect Suspicious Activity The detection and reporting of suspicious activity are central to the AML programs of all US financial services firms, including FCMs and IBs. The specific aspects of a firm s monitoring program normally are tailored to the size of the firm, the nature of its business and client base, and the types of accounts the firm handles. Suspicious activity includes transactions that, in view of the particular customer s business, investment objectives and/or normal trading patterns: Have no obvious business or portfolio purpose; Have no apparent lawful purpose; Are atypical for that customer; Lack a reasonable explanation. In general, it is at the account opening stage, when a firm implements its customer identification program, that the firm identifies potential accounts whose economic or business purpose is not readily apparent. As mentioned previously, at account opening certain types of customer behavior may be considered suspicious, and the firm, if it accepts such an account, may determine that the account requires enhanced scrutiny thereafter. In perhaps the more normal course for many FCMs and IBs, particularly in cases where accounts are not opened in person, it may be only after trading has begun that the firm 3

4 observes suspicious activity, for example, transactions that appear to be inconsistent with what the firm knows about the customer. At such time the firm would determine that the account requires heightened scrutiny. Certain types of transactions normally require heightened monitoring for all customers. These include: Unusual deposits in terms of their size, source, and/or number; Unusual transfers in terms of their size, destination, and/or number; Wash and fictitious trades; Significant third-party transfers and deposits; Significant wire and/or cash deposits or transfers, including individual or a series of transactions involving more than $5,000 in currency or cash equivalents. While there may be valid explanations for such transactional red flags, a futures industry firm should investigate and determine if there is a plausible explanation for each transaction individually and for the transactions in their totality. In all cases of suspected unlawful activity the futures industry firm and its employees must maintain an adequate audit trail. Suspicious Activity Reporting It is the responsibility of futures industry firms to establish clear reporting lines so that all staff members, non-registrants as well as registrants, who are in a position to observe suspicious activity understand how and to whom to report their observations in a timely fashion. NFA Rule 2-9(c) and its accompanying Interpretive Notice require all FCMs and IBs, as part of their AML plans, to designate an individual or individuals to oversee the firm s Anti-Money-laundering Program. Such a compliance officer must be independent and must report ultimately to the firm s senior management The responsibilities of a firm s AML officer include: Investigating suspicious conduct and activity; Evaluating and determining whether such conduct and activity warrant reporting to the firm s senior management; If authorized to do so, reporting such conduct and activity to the U.S. Treasury s Financial Crimes Enforcement Network (FinCEN). Generally, a Suspicious Activity Report by the Securities and Futures Industries (SAR) must be made for any suspicious futures or futures options transaction of $5,000 or more that may involve a violation of law, except for violations that must be reported by FCMs and IBs under futures laws and regulations or the rules of a futures industry self-regulatory organization (SRO). Suspected violations of the Bank Secrecy Act must be reported in a Suspicious Activity Report. A SAR generally should include the following, if known: 4

5 A description of the activity that prompted the report, including the type(s) of activity; The date or range of dates on which the activity took place; A notation whether the transaction was completed or only attempted and whether it was an isolated incident or related to one or more other transactions; An explanation of who benefited from the transaction and how much they received; Other information identifying the transaction, such as its size or dollar amount, currency(ies) involved, where the activity took place, the financial instrument(s) involved, and securities CUSIP or ISID numbers; A description of any admission, explanation, or attempted cover-up of the transaction; Identifying information concerning the account in which the activity took place and/or the account holder; Whether another law enforcement authority has been contacted. As appropriate, a SAR should include recommendations for further investigation that might assist law enforcement authorities. A SAR normally must be made within 30 days of a firm becoming aware of a suspicious transaction, but may be delayed an additional 30 days to identify a suspect. In situations in which timing is critical, immediate telephone contact with appropriate authorities should be made, in addition, to filing a timely written SAR. A copy of the SAR and all supporting documentation must be maintained for five years from the date the SAR was filed. Guidance Regarding the Sharing of SARs and Maintaining Confidentiality Futures industry personnel are barred by federal law from disclosing that a SAR was filed to the person involved in the transaction, the content of a SAR, or to disclose any information that would reveal the existence of a SAR. This disclosure prohibition applies to all persons, except as specifically authorized by regulation 31 CFR The regulation provides that FCMs and IBs are permitted to make SARs and related SAR information available to the National Futures Association (NFA) only upon the request of the Commodity Futures Trading Commission (CFTC). However, in January 2014, the CFTC amended the regulation and requested that all FCMs and IBs to make the following available to upon BFA's request: SARs; Information revealing the existence or non-existence of SARs; and SAR supporting documentation. Such a request may relate to any examination, investigation or for risk assessment purposes. FCMs and IBs may share a SAR, or any information that might reveal the existence of a SAR, with an affiliate, provided that affiliate is subject to a SAR regulation issued by FinCEN or another regulatory agency. These regulatory agencies may include the Board of Governors of 5

6 the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, the Office of Thrift Supervision and the Securities and Exchange Commission. However, the affiliate shall not share the existence of the SAR, or any information that would reveal the existence of the SAR, with another affiliate, even if that affiliate is subject to a SAR rule. In addition, futures industry firms, as part of their internal controls, must have policies and procedures in place which ensure that its affiliates protect the confidentiality of the SAR, including limiting access to a "need-to-know" basis, as well as establishing restricted areas for reviewing SARs, maintaining a log of access to SARs, using cover sheets for SARs or supporting documentation that indicates the filing of a SAR, or using electronic notices that highlight confidentiality concerns before a person may access or disseminate the information. Conclusion Firms and their personnel must ensure that they take adequate steps to identify and verify the identity of their customers, as well as, to detect, deter and report suspicious transactions that could be part of a money-laundering scheme. 6

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