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.
- 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.