• NOTICE OF DISCIPLINARY ACTION

      • #
      • 11-CH-1102
      • Effective Date
      • 22 July 2011
    • 11-CH-1102                                                  

      EXCHANGE DISCIPLINARY ACTION

      CLEARING MEMBER: Eagle Market Makers, Inc.

      CBOT RULE VIOLATION: 981.2. ANTI-MONEY LAUNDERING

      Each clearing member shall develop and implement a written anti-money laundering program approved in writing by senior management reasonably designed to achieve and monitor the clearing member’s compliance with the applicable requirements of the Bank Secrecy Act (31 U.S.C. 5311, et. seq.), and the implementing regulations promulgated thereunder by the Department of the Treasury and, as applicable, the Commodity Futures Trading Commission. That anti-money laundering program shall, at a minimum, 

          2. Provide for independent testing for compliance to be conducted by clearing member personnel or by a qualified outside party.

      FINDINGS: Pursuant to an offer of settlement in which Eagle Market Makers, Inc. neither admitted nor denied the violations, the Clearing House Risk Committee found that Eagle Market Makers, Inc. violated the above rule.

      PENALTY: In accordance with the settlement offer, the Committee imposed a $25,000 fine.

      EFFECTIVE DATE: July 22, 2011