All FCMs must designate a qualified individual or individuals to monitor the firm's day-to-day compliance with its anti-money laundering program. For example, a firm with a full-time compliance officer could designate that compliance officer. The designated individual may not be involved in any functional areas where money laundering or terrorist financing could occur and must ultimately report to senior management. This individual does not, however, have to be a principal of the firm or an Associate Member of NFA.
