CFTC Whistleblower Alert: Be on the Lookout for Violations of the Bank Secrecy Act, Including Failures in AML and SAR Filing Programs
The Whistleblower Office of the Commodity Futures Trading Commission (CFTC) is issuing this alert to inform members of the public about how they may make themselves eligible for both financial awards and certain protections while helping stop those who violate the Commodity Exchange Act by failing to comply with the Bank Secrecy Act (BSA) or related regulations.
What do the BSA and associated regulations require?
Under Financial Crimes Enforcement Network (FinCEN) regulations pertaining to the BSA, Futures Commission Merchants (FCMs) and Introducing Brokers (IBs), whether registered or required to be registered, must comply with various BSA requirements, including, among other things: (1) implementing and maintaining a written anti‐money laundering (AML) program approved by senior management; (2) implementing a written customer identification program (CIP); (3) filing suspicious activity reports (SARs) under certain circumstances; and (4) filing currency transaction reports (CTR).
About the CFTC
We are the U.S. regulator charged with ensuring the integrity of the futures & swaps markets.
About the Whistleblower Program
We will pay 10%‐30% in monetary awards to eligible persons who voluntarily provide us with original information on a Form TCR about violations of the CEA or its rules, if that information leads to a successful CFTC enforcement action resulting in more than $1 million in monetary sanctions. The program also affords confidentiality and anti‐retaliation protections.
For more information go to: www.whistleblower.gov
Commodity Futures Trading Commission
1155 21st Street, NW
Washington, DC 20581
This article was prepared by the Commodity Futures Trading Commission’s Whistleblower Office. This article is provided for general informational purposes only and does not provide legal or investment advice to any individual or entity. It is not intended to, does not, and may not be relied upon to create any rights, substantive or procedural, enforceable by any party in any matter, civil or criminal. Please consult with your own legal adviser before taking any action based on this information. Please note that the above lists of relevant requirements or types of misconduct are not exhaustive.