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CFTC Issues Advisory Regarding Suspicious Activity Reporting and Economic Sanctions Programs
Friday, July 8, 2016

On July 6, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) published Staff Advisory No. 16-60 (Advisory), which reminds futures commission merchants (FCMs) and introducing brokers (IBs) of their obligations to report certain kinds of suspicious activities. The Advisory notes that FCMs and IBs must file suspicious activity reports with the Financial Crimes Enforcement Network no later than 30 calendar days after detecting such suspicious activity (subject to limited exceptions). It also reminds all CFTC registrants of their obligations to monitor and comply with Office of Foreign Asset Control (OFAC) economic sanctions programs (including prohibitions on dealing with persons included in OFAC’s list of Specially Designated Nationals and Blocked Persons). DSIO noted that such reporting requirements assist regulators in identifying patterns and trends of illegal activities, such as money laundering and terrorist financing.

A copy of the Advisory is available here.

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