NFA Reminds Members of Effective Date for Amendments to Information Systems Security Program Requirements

On March 1, the National Futures Association (NFA) published Notice I-19-07 (Notice), alerting Members that April 1 will be the effective date for amendments to NFA’s Interpretive Notice entitled NFA Compliance Rules 2-9, 2-36 and 2-49: Information Systems Security Programs (Interpretive Notice). (For a discussion of such amendments, please refer to the January 11, 2019 edition of Corporate & Financial Weekly Digest.) The Notice reminded Members that certain cybersecurity incidents discovered on or after April 1 must be reported to NFA, as further set out in the updated Interpretive Notice.

The Notice is available here.

NFA Issues Notice Regarding Updated FinCEN AML/CFT Guidance

On March 12, the National Futures Association (NFA) published Notice I-19-08, notifying Member futures commission merchants (FCMs) and introducing brokers (IBs) of a March 8 advisory published by the Financial Crimes Enforcement Network (FinCEN) regarding updates to the Financial Action Task Force’s list of jurisdictions with deficiencies regarding anti-money laundering and combating the financing of terrorism (AML/CFT). The advisory includes specific updates regarding AML/CFT compliance issues related to the Democratic People’s Republic of Korea, Iran and Cambodia. NFA reminds member FCMs and IBs to review the aforementioned advisory and revise, if necessary, their respective AML programs to comply with the new guidance.

Notice I-19-08 is available here.

The FinCEN advisory is available here.