Turnkey Trading Partners always likes to remind our clients to consider annual compliance deadlines and obligations.  This year saw both the Commodity Futures Trading Commission (“CFTC”) as well as National Futures Association (“NFA”) roll out a number of new compliance and regulatory changes.  They also increased enforcement efforts and have been significantly more active regulating communications supervision and cybersecurity than in years past.

2023 NFA Annual Obligations

  1. Update/Review Compliance Manual as applicable
  2. Annual privacy notice to customers (consider changes to policy)
  3. For IB’s update and obtain New FCM AML reliance agreements.
  4. Complete NFA’s Annual Questionnaire  
  5. Pay NFA Dues and update all registration information
  6. Complete NFA’s Self-Examination Questionnaire  for main office and branch offices
  7. Ensure branch and GIB locations have been audited within the calendar year (call Turnkey for help!)
  8. Conduct all trainings necessary such as Anti-Money Laundering (“AML”), Ethics, Cybersecurity, Identity Theft training for relevant employee
  9. Test your Cyber Security and Disaster Recovery Plan and make any necessary adjustments.
  10. Implement Third – Party Service Provider Policies and Risk Assessment

If you have any questions or concerns with your compliance program, please contact Turnkey today via (312) 324-0040 or by clicking here. Our team can conduct mock audits for your firm and fully assist with ensuring 2024 is your best year of compliance yet.

2023 Year In Review

If you have not done so sign up for Turnkey’s Newsletter which is sent monthly. We don’t sell or share customer information and we provide industry leading CFTC and NFA compliance content each month. The following are articles we have written in 2023. The topics range from new approaches from regulators to the newest frauds such as Pig-Butchering scams.

Building A Robust CFTC and NFA Record Keeping Program

Critical CFTC Supervision and Record Keeping Tips

Cyber Alert: “Pig Butchering” Education

Annual Attestation Anxiety: A Guide To Supervisory Reviews

Block Trades, Voice, Chat, & OTC Brokerage

Renewables: Uncertain Regulations Equal Uncertain Markets

Is “Working From Home” A Compliance Time Bomb?

Revisiting NFA Bylaw 1101

CFTC, NFA Trading Performance Interest Calculations

NFA’s First Crypto Regulations

2023 Regulatory Examination and Audit Expectations

Eight Secrets No One Shares with A New CTA