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NFA Rule 2-9

Requires effective supervision of personnel and, for Futures Commission Merchants (FCO) and Introducing Brokers (IB), a comprehensive AML compliance program.

Rule Overview

Jurisdiction: United States

Regulator: National Futures Association (NFA)

Topic: Supervision

NFA Rule 2-9
Overview
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Further Reading

Key requirements:

  • Requires FCO, IB, Commodity Pool Operator (CBO), and Commodity Trading Advisor (CTA) Members, and supervisory Associates, to diligently supervise employees and agents involved in commodity interest activities. Swap Dealer and Major Swap Participant Members have the same duty for swap activities.
  • The NFA may require certain Members to adopt enhanced supervisory procedures, based on factors such as associated person or principal employment history, or customer charges. Members may seek a waiver by showing their existing procedures provide effective supervision.
  • FCMs and IBs must maintain a written, senior management-approved AML program that includes:
    • internal controls;
    • independent testing;
    • designated compliance personnel;
    • ongoing training;
    • risk-based customer due diligence; and
    • ongoing monitoring to identify and report suspicious transactions.

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