AML Policy (Anti-Money Laundering)

Overview CME Group's Anti-Money Laundering (AML) Policy is codified in Rule 981 of the CME Rulebook. It is designed to ensure that CME Group's clearing members comply with all applicable anti-money laundering and economic sanctions laws, including the Bank Secrecy Act, the International Emergency Economic Powers Act (IEEPA), and the Trading with the Enemy Act (TWEA). Compliance Program Requirements Each clearing member shall develop and implement a written compliance program approved in writing by senior management. The program must be reasonably designed to achieve and monitor the clearing member's compliance with all applicable requirements of the Bank Secrecy Act (31 U.S.C. § 5311 et seq.), IEEPA (50 U.S.C. § 1701 et seq.), TWEA (50 U.S.C. App. § 1 et seq.), and the Executive Orders and regulations issued pursuant thereto, including regulations issued by the U.S. Department of the Treasury and the Commodity Futures Trading Commission. The compliance program must, at a minimum, include the following five elements: #Requirement 1 Establish and implement policies, procedures and internal controls reasonably designed to prevent the financial institution from being used for money laundering or the financing of terrorist activities 2 Provide for independent testing for compliance to be conducted by clearing member personnel or by a qualified outside party 3 Designate an individual or individuals responsible for implementing and monitoring the day-to-day operations and internal controls of the program 4 Provide ongoing training for appropriate personnel 5 Include appropriate risk-based procedures for conducting ongoing customer due diligence Customer Due Diligence Risk-based procedures for ongoing customer due diligence must include: • Understanding the nature and purpose of customer relationships for the purpose of developing a customer risk profile • Conducting ongoing monitoring to identify and report suspicious transactions • On a risk basis, maintaining and updating customer information, including information regarding the beneficial owners of legal entity customers Supervision of Introducing Brokers Clearing members must also supervise and ensure that their guaranteed introducing brokers are in compliance with the provisions contained in Rule 981. Regulatory Framework CME Group's AML compliance framework is aligned with: • The Bank Secrecy Act (BSA) • Financial Crimes Enforcement Network (FinCEN) regulations • CFTC requirements for Futures Commission Merchants (FCMs) • U.S. Treasury Department regulations • International Emergency Economic Powers Act (IEEPA) • Trading with the Enemy Act (TWEA)