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Rule Interpretations and Training
January 25, 2006
Contact:  Rick Farber - 212-306-5310

Reg 2006-04 Rulings
Amex Periodic Anti-Money Laundering Seminar - Dates in 2006

 
The purpose of this Notice is to inform all members and member organizations that conduct business exclusively with registered broker-dealers ("Firms") that the Exchange's periodic Anti-Money Laundering ("AML") Seminar will be held on the following dates in 2006. The seminars will be held in the Amex boardroom located on the 14th floor of 86 Trinity Place.
DateTime
Monday, January 304:30 p.m.
Wednesday, March 158:30 a.m.
Thursday, May 114:30 p.m.
Monday, June 194:30 p.m.
Thursday, September 218:30 a.m.
Wednesday, November 158:30 a.m.
Tuesday, December 194:30 p.m.
By attending at least one of the Exchange's periodic AML Seminars each year, employees of firms that have elected to utilize the Exchange's AML seminar to satisfy the Anti-Money Laundering training requirement will maintain compliance with the training component of Amex Rule 432.1 Each seminar will last approximately one-half hour and will satisfy the requirement that firms "Provide ongoing training for appropriate persons" pursuant to Amex Rule 432. The Seminar will cover various topics, rules and regulations relating to Amex Rule 432, the USA PATRIOT Act of 2001 and other related anti-money laundering requirements. Under Federal law these provisions are applicable to your firm, regardless of whether your firm maintains customer accounts.

Employees of member organizations who do not have valid Amex IDs must pre-register in order to gain access to the building on the day of the seminar. Please call the undersigned at least two business days before the seminar you wish to attend.

Please call Rick Farber at 212-306-5310 to pre-register, or if you have any questions about this Notice.


1Amex Rule 432
Exchange Rule 432 requires that each member organization and each member not associated with a member organization develop and implement written anti-money laundering programs reasonably designed to achieve and monitor compliance with the requirements of the Bank Secrecy Act (31 U.S.C. 5311, et seq.) and the implementing regulations promulgated thereunder, which program must be approved in writing by a member of senior management. At a minimum, such program must:
  1. Establish and implement policies and procedures that can be reasonably expected to detect and cause the reporting of suspicious financial transactions as required under 31 U.S.C. 5318(g) and the implementing regulations thereunder;
  2. Establish and implement anti-money laundering policies, procedures and internal controls reasonably designed to achieve compliance with the Bank Secrecy Act and the implementing regulations thereunder;
  3. Provide for independent testing for compliance of the above procedures to be conducted by member or member organization personnel or by a qualified outside party;
  4. Designate a person or persons responsible for implementing and monitoring the day-to-day operations and internal controls; and
  5. Provide ongoing training for appropriate persons.