AML Procedures System

Futures commission merchants (FCM) and introducing brokers (IB) are required to establish a written anti-money laundering (AML) compliance program that meets the requirements of the Bank Secrecy Act (BSA) and NFA Compliance Rule 2-9(c). The AML Procedures System is designed to assist Members in developing a written compliance program and providing further information on the minimum components of a program and examples of suggested language.

This system is intended to provide an outline for the program and modifications may be necessary to address the AML risks associated with a particular Member's business. FCMs and IBs are not required to use this system to develop their AML program. Using the system does not guarantee that your program will satisfy the AML program requirements, nor does it provide a safe harbor from violations of the program requirements.