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Housekeeping

Housekeeping, Reminders & Updates - Feb 2018

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Written by: Mark E. Ruddy, Esq. Maria Fielding The National Futures Association (“NFA”) Adds Additional Questions on the Annual Financial Statement The NFA announced that as of October 31, 2017, there will be two additional yes/no questions added to the Annual Financial Statement. Both questions are related to virtual currency activities. The NFA announced the additional questions in Notice to Members I-18-03. Financial Crimes Enforcement Network (“FinCEN”) Updates Jurisdictions with Deficiencies On February 9, 2018, FinCEN released an advisory updating their list of strategic anti-money laundering (“AML”) and combatting the financing of terrorism (“CFT”) deficiencies. Notably, Sri Lanka, Trinidad and Tobago, and Tunisia were added to the “Improving Global AML/CFT Compliance: On-Going Process” list while Uganda was removed. Bosnia and Herzegovina, Ethiopia, Iraq, Syria, Vanuatu, and Yemen are all currently remaining on the list. No changes occurred regarding Democratic People’s Republic of Korea and Iran, which are currently recommended that jurisdictions impose countermeasures and enhance due diligence, respectively. The Advisory is available in its entirety through the FinCen website. Commodity Futures Trading Commission (“CFTC”) Releases Virtual Currency Advisory On February 15, 2018, the CFTC released an advisory regarding possible scams surrounding the buying and selling of virtual currencies. Specifically, the CFTC warns of “pump-and-dump” schemes where victims will buy the currency due to rising prices only to have the price dramatically fall within a short period of time. The CFTC states that they have already received complaints from customers who have lost money to these schemes. The CFTC suggests customers remain vigilant when researching virtual currencies and to be cautious when considering price spikes and social media reviews of such currencies. More details on the advisory can be found within the CFTC Press Release pr7697-18. For further information about any of the topics covered, please feel free to contact Ruddy Gregory, PLLC (www.ruddylaw.com) or 202-797-0762.  

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