Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 25 JUNE 2018

NFA Proposes Adding Customer Due Diligence Rule To AML Program Requirements

Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
Contributor
Hogan Lovells Cadwalader

Hogan Lovells Cadwalader

Hogan Lovells Cadwalader is a global law firm trusted by clients to deliver on complex, high-stakes...

View firm profile
Explore more from Hogan Lovells Cadwalader

The National Futures Association proposed amending its anti-money laundering ("AML") program requirements for futures commission merchants ("FCMs") and introducing brokers ("IBs") ...

United StatesGovernment, Public Sector
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
Author LinkedIn connections

The National Futures Association proposed amending its anti-money laundering ("AML") program requirements for futures commission merchants ("FCMs") and introducing brokers ("IBs") to include risk-based procedures for conducting customer due diligence. The amended NFA Compliance Rule 2-9(c) and Interpretive Notice " Compliance Rule 2-9: FCM and IB Anti-Money Laundering Program" would conform to the Customer Due Diligence Rule ("CDD Rule") implemented by the Financial Crimes Enforcement Network ("FinCEN") that went into effect on May 11, 2018. The amendments will become effective ten days following receipt of the submission by the CFTC, unless otherwise determined.

Once effective, the amendments will require FCMs' and IBs' written AML programs to include procedures to (i) verify the identity of the beneficial owners of legal entity customers for which new accounts are opened on or after May 11, 2018, (ii) understand the nature and purpose of customer relationships

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

See more popular content from

Article

SBA Extends Deadline For Comments On Historic Overhaul Of Size Standards

The Small Business Administration has extended the comment period for two proposed rules that could dramatically reshape federal government contracting by significantly expanding the pool of entities eligible for small business set-aside procurements. With some size standard thresholds proposed to increase as much as tenfold, these changes would fundamentally alter the makeup of the small business contractor base.
United StatesGovernment, Public Sector
Crowell & Moring LLP
Crowell & Moring LLP
Article

Tennessee 2026 Midterm Election Results: Blackburn Wins Governor’s Race Amid Congressional And Legislative Upsets

Tennessee's 2026 midterm elections brought unexpected shifts to the state's political landscape, with Marsha Blackburn winning the governorship by the narrowest margin in over a century and Democrats flipping six House seats despite Republican supermajority retention. The results set the stage for significant leadership changes and new policy priorities when the 115th General Assembly convenes in January 2027.
United StatesGovernment, Public Sector
Bass, Berry & Sims PLC
Bass, Berry & Sims PLC
Article

D.C. Circuit Rules Pentagon Can Exclude Anthropic From Supply Chain

The U.S. Court of Appeals for the D.C. Circuit has ruled that the Department of War can exclude Anthropic from its supply chain under the Federal Acquisition Supply Chain Security Act, finding that the AI company's ability to manipulate its Claude model creates a supply chain risk. This decision contrasts with an earlier California district court ruling that blocked a similar designation under a different statute, creating a complex legal landscape for AI providers and government contractors.
United StatesGovernment, Public Sector
Taft, Stettinius & Hollister LLP
Taft, Stettinius & Hollister LLP
Article

State AG News: Consumer Fraud And Deceptive Practices (October 1-7, 2026)

State attorneys general across the nation are taking decisive legal action on multiple fronts, from challenging federal fuel economy rollbacks to pursuing pharmaceutical companies over misleading drug claims. This week's enforcement activities reveal coordinated multistate efforts alongside individual state actions targeting consumer protection, national security concerns, and social media platform accountability.
United StatesGovernment, Public Sector
Crowell & Moring LLP
Crowell & Moring LLP
Article

BIOSECURE Act Update: Court Enjoins WuXi AppTec’s 1260H Designation, but Strategic and Compliance Clocks Keep Running

The U.S. District Court for the District of Columbia has preliminarily enjoined the Department of War from enforcing WuXi AppTec's Section 1260H designation, finding the agency misread its evidence on state and military affiliation. However, this ruling does not close alternative pathways to biotechnology company of concern (BCC) designation under the BIOSECURE Act, and earlier supply-chain restrictions continue to drive near-term compliance decisions with a critical June 30, 2027 deadline for sub-tier supp
United StatesGovernment, Public Sector
Greenberg Traurig
Greenberg Traurig
Article

FMCSA MOTUS Implementation – Common Motor Carrier Concerns

The Federal Motor Carrier Safety Administration launched MOTUS in May 2026, replacing legacy registration platforms and fundamentally changing how motor carriers, freight brokers, and surface freight forwarders handle operating authority applications and license maintenance. While designed to combat fraud and streamline registration activities, the transition has created significant user experience challenges that threaten operating authority status and customer relationships for transportation service prov
United StatesGovernment, Public Sector
Benesch, Friedlander, Coplan & Aronoff LLP
Benesch, Friedlander, Coplan & Aronoff LLP
Article

The Next Chapter Of Digital Accessibility: FCC Seeks Input On Modernizing Its Rules

The Federal Communications Commission is seeking public feedback on modernizing its accessibility framework to address rapid changes in consumer technology. The draft Notice of Proposed Rulemaking examines whether existing rules keep pace with today's communications marketplace or inadvertently hinder innovation in accessibility solutions.
United StatesMedia, Telecoms, IT, Entertainment
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
Article

New York City Rent Freeze Faces Legal Challenge As Court Considers Landlords’ Claims

Landlords of rent stabilized buildings in New York City have filed a lawsuit challenging the rent freeze passed by the Rent Guidelines Board, questioning the Board's independence and data integrity. With operating costs rising 31% over five years while the Board voted 7-1 for a freeze affecting 1 million apartments, the case raises critical questions about the balance between tenant protection and landlord viability.
United StatesReal Estate and Construction
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
Article

FCC Updates TCPA Consent Revocation Rules, Seeks Comment On Further Changes

The Federal Communications Commission has amended its TCPA consent revocation rules, introducing category-specific opt-outs for informational robocalls and allowing callers to designate exclusive revocation methods. The changes aim to balance consumer control with operational flexibility while addressing concerns about the previous "revoke all" requirement that could inadvertently block wanted communications like fraud alerts and security notifications.
United StatesMedia, Telecoms, IT, Entertainment
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
Article

ARPA-H To Expedite Clinical Trials With SURPASS And Other AI Related Programs

The U.S. Advanced Research Projects Agency for Health has launched SURPASS, a groundbreaking program designed to revolutionize clinical trial design through AI-powered simulations, real-time data analysis, and adaptive modifications. How will these innovations reshape pharmaceutical development timelines and maintain America's competitive position in the global drug development landscape?
United StatesFood, Drugs, Healthcare, Life Sciences
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
Article

FRB Vice Chair For Supervision Bowman Announces Five-Region Supervisory Structure And Further Regulatory Reforms

Federal Reserve Vice Chair Michelle Bowman has announced a major restructuring of the Federal Reserve's supervisory function into five regional divisions, moving away from the current twelve Reserve Bank district model. The reorganization aims to address accountability concerns identified in the Silicon Valley Bank failure review, while Bowman also previewed significant changes to regulatory thresholds, the large bank tailoring framework, and supervisory ratings.
United StatesFinance and Banking
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader