CBOE AML Compliance Program

• 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.

Application

• 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.

Effectiveness

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