CBOE AML Compliance Program

On Feb. 14, CBOE issued AML due diligence for permit holders.

  • Follows 2016 FinCEN rules, on customer due diligence requirements.
  • Require trading permit holders be in compliance with CDD rules by May 11, 2018.
  • Must have written AML program, designed to achieve compliance with CDD rules.


  • Where TPH is not a FINRA member, and CBOE is designated examining authority,
    and not required to file monthly FOCUS reports, are the only entities it applies to.
  • If TPH is registered broker-dealers, then applied, even if not now actively trading.

Filing Requirements

  • File written procedures for AML compliance program, sign by senior management
  • Compliance attestation, evidence annual AML training, independent review letter.


  • Must file no later than Apr. 2, 2018, and submit by email to the exchange as well.