Teacher and consultant to the futures industry since 1983
Teacher and consultant to the
futures industry since 1983
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Items you need to improve and protect your FCM or IB... 1. Very important and useful forms and letters for different applications for the FCM and the Introducing Broker. Visit our "forms" page. |
ANTI-MONEY LAUNDERING ANNUAL REVIEWAs you read this, ask yourself if it is time that you have Investment Reference discuss this further with you and assist you with all the requirements... Unlike many of the procedures you, as an FCM or IIB, are required to have by the NFA, the Anti-Money Laundering procedures are mandated by the Patriot Act and the Bank Secrecy Act. Many IBs are just not aware of the severe penalties that have been handed down by the NFA for certain violations concerning Anti-Money Laundering. As a GIB, you must not only have the procedures of your guaranteeing FCM, but you must also have taken several steps to prove that your firm has adopted those procedures, will adhere to them, have appointed an AML Compliance Officer, have proof that your Associated Persons have read, have a strong working knowledge of them and attest to follow them, have had proof of an annual AML review by a party not involved with your firms program and have proof of completion of the annual AML training, just to name a few. As an Independent Introducing Broker, your requirements are even more in depth. In fact, the NFA will not even approve your IIB for operation unless and until you have submitted your procedures to them for acceptance. Remember, the NFA never approves anything because what the management level person tells you in the main office may be overridden by their audit team in the field. Therefore even though your procedures are "accepted" by the reviewing staff in the NFA office, that does not mean (and has not meant) that the field audit team will not cite you for a violation. Penalties, some seemingly minor, for not properly instituting and following AML procedures have been as great as $30,000. Although there are guides for such procedures, the NFA guides do not cover all the required points and the NFA has been inconsistent with their assistance in the creation of the procedures and their auditors inconsistent in their field reviews of them. Therefore any minor and innocent oversight on your part could be very costly, and, as a small IB, even put you out of business. We at Investment Reference Have been doing AML procedure reviews since their inception in 2002. We do the required internal annual review for many FCMs, IIBs and GIBs. As with our field audits of futures firms, our AML reviews are comprehensive, honest and intended to not only find the problem areas, but also assist you in correcting these problems so that you are in compliance with the requirements. Our reviews have been accepted by the NFA, the CFTC, the CBOT and the CME. This procedure is a very important one and we at Investment Reference are very strongly behind the enforcement of the requirements. In our hundreds of reviews conducted for FCMs and IBs, we have seen this program work and have seen evidence of money laundering attempts on several occasions. In some of the cases, it appeared to be strong evidence of attempted money laundering by terrorist factions within and without the U.S. Get in touch with us by
email.
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