The USA Patriot Act of 2001, section 352, requires NFA Member futures commission merchants (FCMs), brokers (IBs) and NASD broker/dealer firms to have anti-money laundering (AML) compliance programs in place as of April 24, 2002. For your convenience we´d like to highlight the important elements of AML compliance requirements, and explain how our training programs and audit/consulting services through our affiliate EA Compliance can fully meet all requirements of the CFTC, SEC, NFA and FINRA.

In summary, the USA Patriot Act of 2001 requires the following:

• Development of internal policies, procedures and controls.
• Designation of a Compliance Officer at your firm
• Ongoing employee training program
• Independent audit function to test your AML programs

Most large firms have written procedures in placed already. While your firm should have a plan which meets your needs, we have a prototype (or template) as an example.

Development of Internal Policies, Procedure and Controls

Our affiliate EA Compliance can assist your firm with developing your internal policies, AML procedures, programs and controls. AML compliance is their focus and they bring you both experience and expertise in the area.

Designation of a Compliance Officer at your firm

Your firm must designate one person as your AML Compliance Officer, and have that person register as such with either the NFA or NASD. This person is responsible for ensuring your firm’s compliance with all federal, state and regulatory responsibilities under the USA Patriot Act.

Ongoing employee training program

Regulated financial institutions must provide ongoing education and training for all appropriate personnel. At a minimum, a firm should provide annual training on the firm´s policies and procedure, the relevant federal laws and regulatory AML requirements. Firms should also maintain records to evidence their compliance with this requirement.

Ongoing AML training programs for your staff are available immediately online. We are the world’s largest provider of compliance training programs to the futures industry and serve most of the world’s largest financial firms.

Please see our AML training course outline and provider qualifications.

Independent audit function to test your AML program

Regulated financial institutions must conduct annual testing of their AML compliance program. This testing can be done by a firm´s personnel (such as an internal audit staff) who are independent of the personnel working in areas that are exposed to potential money laundering risks or by hiring an outside party with experience in this type of audit. The results of this audit should be documented and reported to the firm´s senior management or an internal audit committee.

Our affiliate EA Compliance will perform an independent, third-party performance audit of your company’s AML program. EA Compliance provides a fully documented audit and will submit their findings in a report to your firm’s senior management or internal audit committee along with appropriate recommendations and suggestions. EA Compliance is a fully qualified, industry experienced provider of these services.

We would welcome the opportunity to help your firm meet your AML compliance obligations and assure you that we offer the most efficient, cost effective AML compliance solution available. If you have any questions please do not hesitate to call us at 800-823-8442 or email us at exch@xanalytics.com

Our AML training course is competitively priced at $25 and is available immediately online. Volume discounts are available. Price includes reporting, certification, record-keeping, and everything you’ll need for regulatory purposes.