This month’s coordinated U.S. multi-agency enforcement action against online broker Interactive Brokers (IBKR) signals authorities’ ongoing concerns about anti-money laundering/combating the financing of terrorism (AML/CFT) risk in the securities and commodities sectors and underlines the need for capital markets participants to design and implement comprehensive AML/CFT programs. The U.S. Securities Exchange Commission (SEC), Financial Industry Regulatory Authority (FINRA), and Commodities Futures Trading Commission (CFTC) fined IBKR a total of $38 million for failure to implement an effective AML/CFT program. The CFTC noted that “this case marks the first CFTC enforcement action charging a violation of Regulation 42.2, which requires registrants to comply with the Bank Secrecy Act (BSA).”