FINANCIAL AND REGULATORY BULLETIN

TO:                  Chief Executive Officers                                                                                #14-02

                        Chief Financial Officers                                                                              

                        Chief Compliance Officers

DATE:             February 14, 2014

SUBJECT:      Suspicious Activity Reports

In accordance with regulations issued by the Financial Crimes Enforcement Network interpreting the Bank Secrecy Act, futures commission merchants (“FCMs”) and introducing brokers (“IBs”) are prohibited from disclosing information pertaining to either the existence or non-existence of suspicious activity reports (“SARs”) to an SRO unless requested by the Commodity Futures Trading Commission (“CFTC”).  In a January 8, 2014 letter provided by the CFTC (attached), FCMs and IBs are requested to now make the following available to CME, if requested by CME:

·         SARs;

·         Information revealing the existence or non-existence of SARs; and,

·         SAR supporting documentation.

The letter also specifies that although commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) are not required to file SARs, for any SARs voluntarily filed by a CPO or CTA, the CPO and/or CTA must make the above noted information available to the Commission upon request of CME.

Such requests may be in relation to any examination, investigation or for risk assessment purposes.

If you have any questions, please contact the Financial and Regulatory Surveillance Department at (312) 930-3230.