4/01/2005 USA PATRIOT Act Monitor News Release: CFTC Issues
Customer ID Program Ruling
In CFTC Letter No. 05-05 (available at www.cftc.gov/files/tm/letters/05letters/tm05-05.pdf), the Commodity Futures Trading Commission granted a ruling request, providing that under specified circumstances futures commission merchants (FCMs) and introducing brokers (IBs) may rely on commodity trading advisors to perform customer identification program functions. This ruling parallels a similar ruling made by the SEC in 2004, which permitted brokers and dealers to rely on investment advisers registered with the SEC to perform elements of the BD's CIP (covered in the April 2004 Monitor). Although registered with the CFTC or the SEC (as investment advisers), CTAs are not yet subject to AML program rules, though proposed rules have been issued. This ruling, and the current status of such CIP sharing arrangements, will be addressed in the April issue of the Monitor.
USA PATRIOT ACT MONITOR is published by Civic Research Institute, Inc., 4478 U.S. Route 27, P.O. Box 585, Kingston, NJ 08528, 609-683-4450, firstname.lastname@example.org, as an update service for Money Laundering, Terrorism and Financial Institutions: Law · Regulation · Compliance · USA PATRIOT Act Monitor © 2004 Civic Research Institute, Inc. All rights reserved. Unauthorized copying expressly prohibited. The information in this publication is not intended to replace the services of a trained legal professional. Neither the editors, nor the contributors, nor Civic Research Institute, Inc. are by this publication engaged in rendering legal, accounting, or other professional services. The editors, contributors, and Civic Research Institute, Inc., specifically disclaim any liability, loss, or risk, personal or otherwise, which is incurred as a consequence, directly or indirectly, of the use or application of the contents of this publication.
<< News Releases Main Page