The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight issued an advisory to remind futures commission merchants and introducing brokers of their ongoing obligation to report suspicious activities, as required by the Financial Crimes Enforcement Network, and for all registrants to comply with economic sanction programs administered by the Office of Foreign Assets Control. (Both FinCEN and OFAC are part of the US Department of Treasury.)

Compliance Weeds: FinCEN recently expanded its existing anti-money laundering and customer identification program requirements for FCMs, IBs and other covered financial institutions by finalizing rules requiring them to identify the material beneficial owners of their legal entity customers based on tests of equity ownership and control. Such entities are currently required to know the identity of each of their legal entity customers, but not necessarily their beneficial owners. (Click here for more details in the article, “FinCEN Finalizes Rules Requiring Banks, Broker-Dealers, FCMs, Mutual Funds and IBs to Help Verify Beneficial Owners of Certain Accounts” in the May 8, 2016 edition of Bridging the Week.)