AML Program Changes – Deadline Looms

Have you updated your AML Program to comply with the FinCEN changes going into effect on May 11, 2018? Most Futures Commission Merchants (“FCMs”) have implemented changes to their Anti-Money Laundering Programs (“AML Programs”) in accordance with the Financial Crimes Enforcement Network’s (FinCEN) final rules issued on July 11, 2016. These FinCEN final rules must be incorporated into all FCM and Introducing Broker (“IB”) AML Programs by May 11, 2018. Introducing Brokers will need to fulfill this obligation within their own AML Programs even if they rely on their FCMs for certain aspects of the program. Specifically, these firms will…

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