On April 8, the National Futures Association (NFA) published Notice I-20-17, notifying Member futures commission merchants (FCMs) and introducing brokers (IBs) of two recent issuances from the Financial Crimes Enforcement Network (FinCEN). The NFA encourages Member FCMs and IBs to carefully review both of the following releases to assess any impact they might have on their anti-money laundering (AML) programs and regulatory obligations.

First, the NFA called attention to FinCEN’s April 3 notice regarding compliance with the Bank Secrecy Act (BSA) and AML obligations in the midst of the COVID-19 pandemic. The notice includes direct contact instructions should a financial institution need to contact FinCEN regarding urgent issues related to COVID-19. Additionally, the notice addresses modifications to Currency Transaction Report filing requirements and emphasizes the potential role of novel approaches in meeting BSA and AML responsibilities. The notice also addresses certain aspects of beneficial ownership requirements and the CARES Act.

The notice is available here.

Second, the NFA highlighted FinCEN’s March 26 advisory announcing updates to the Financial Action Task Force’s list of jurisdictions with deficiencies regarding AML and combating the financing of terrorism (CFT). The advisory also includes specific updates regarding AML/CFT compliance issues related to the Democratic People’s Republic of Korea and Iran.

The advisory is available here.