The NFA issued an Interpretive Notice regarding NFA Compliance Rule 2-9 ("Supervision") and its requirement for all financial institutions, including futures commission merchants ("FCMs") and IBs, to establish anti-money laundering ("AML") programs. The purpose of the Interpretive Notice is to highlight the minimum standards of AML programs and provide NFA Member FCMs and IBs with additional guidance on satisfying the requirements of NFA Compliance Rule 2-9(c). Compliance Rule 2-9(c) states that AML programs must, at a minimum, include internal policies, procedures, and controls; a designated

The NFA submitted to the CFTC its proposed amendments to NFA's Code of Arbitration regarding the consolidation of arbitration claims involving customer segregated funds losses. See: NFA Proposed Amendments.

The Futures Industry Association ("FIA") released an empirical study on changes in the level of volatility in futures markets. The study focused on 15 futures contracts listed on four futures exchanges: CME Group, Eurex, Intercontinental Exchange and NYSE Liffe. The study found that while prices in these 15 markets moved through high and low cycles of volatility and experienced numerous spikes due to macro-economic events, volatility attributable to structural factors did not change in most of these contracts. According to the study, innovations such as algorithmic and high-frequency trading

The SEC Office of Compliance Inspections and Examinations ("OCIE") issued a Risk Alert, on business continuity and disaster recovery planning for investment advisers, which was prompted by a review of responses to Hurricane Sandy. The alert follows a joint advisory issued on August 16 by OICE, the CFTC's Division of Swap Dealer and Intermediary Oversight, and FINRA; however, this Risk Alert focuses exclusively on investment advisers. The alert makes observations in the following areas: Preparation for widespread disruption; Planning for alternative locations; Preparedness of key vendors

The United Kingdom recently issued an updated version of its Guidance Notes for the Implementation of the FATCA Intergovernmental Agreement ("IGA") with the United States. The revisions to the 142-page document essentially reflect the delayed effective dates under FATCA announced by the U.S. Treasury on July 12, 2013, as well as modifications to Annex II to the IGA. The Guidance Notes also provide that if the United States subsequently amends the underlying FATCA Regulations (which is likely) to introduce additional or broader exemptions, the UK will consider whether to incorporate these