Refco and Introducing Sample Clauses

Refco and Introducing. Firm shall adhere to the terms of the No Action Letter, including the Interpretations as set forth therein, in all respects.
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Refco and Introducing. Firm have each established, implemented and shall enforce and maintain a written anti-money laundering compliance program ("AML Program") as required by the USA PATRIOT Actss.352 and the rules of any applicable self-regulatory organizations (NASD Rule 3011). Such program is reasonably designed to achieve and monitor such party's ongoing compliance, to the extent applicable, with the BSA and implementing regulations promulgated thereunder. Such program consists of, at a minimum: establishment of policies, procedures and controls that can be reasonably expected to detect and cause the reporting of suspicious transactions; designation of an employee responsible for implementing and monitoring the program; employee training; and independent testing for compliance. Introducing Firm and Refco shall notify such party's relevant self-regulatory organization of its designated AML officer.

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