Adhere to ethical standards fair dealing practices and disclosure requirements in all business activities.

• Maintain Ethical Standards and Fair Practices - BC.A

  Establish and uphold high ethical standards and ensure fair treatment of all clients and counterparties.

• Ethical Standards Policy - BC.A.1

  Establish and maintain a written policy outlining ethical standards for all personnel.

• Fair Dealing Procedures - BC.A.2

  Implement procedures to ensure fair dealing with customers and counterparties.

• Ensure Compliance with Disclosure Requirements - BC.B

  Adhere to all regulatory obligations related to providing necessary information to clients.

• Disclosure Requirements Compliance - BC.B.1

  Comply with all NFA rules and CFTC regulations regarding disclosure of information to customers.

Meet minimum capital requirements and maintain accurate financial records as mandated by the NFA.

• Meet and Maintain Minimum Capital Requirements - FR.A

  Ensure the firm possesses sufficient capital to meet its financial obligations and regulatory requirements.

• Minimum Capital Compliance - FR.A.1

  Maintain capital levels at or above the minimum requirements set by the NFA.

• Ensure Accurate Financial Record Keeping - FR.B

  Establish and maintain comprehensive and accurate records of all financial transactions and activities.

• Accurate Record Keeping - FR.B.1

  Maintain accurate and complete financial records in accordance with NFA rules.

Implement robust compliance and supervisory systems to ensure adherence to NFA rules and CFTC regulations.

• Implement a System of Written Supervisory Procedures - CS.A

  Develop and maintain documented procedures that outline the supervisory responsibilities within the firm.

• Written Supervisory Procedures (WSPs) - CS.A.1

  Develop and implement written supervisory procedures outlining the responsibilities of supervisory personnel.

• Conduct Regular Supervisory Reviews - CS.B

  Establish a schedule and methodology for reviewing the effectiveness of the firm's supervisory framework.

• Supervisory Reviews - CS.B.1

  Conduct regular reviews of the firm's supervisory systems to identify and address potential compliance issues.

Establish and maintain an Information Systems Security Program (ISSP) to protect sensitive information and systems.

• Establish and Maintain an Information Systems Security Program (ISSP) - CY.A

  Implement a comprehensive program designed to protect the confidentiality integrity and availability of the firm's information assets.

• ISSP Development and Implementation - CY.A.1

  Develop a written ISSP that addresses risk assessment security controls incident response and employee training.

• Cybersecurity Risk Assessment - CY.A.2

  Conduct regular assessments to identify and evaluate cybersecurity risks to the firm's systems and data.

• Cybersecurity Incident Response Plan - CY.A.3

  Develop and maintain an incident response plan to address cybersecurity incidents.

• Employee Cybersecurity Training - CY.A.4

  Provide regular cybersecurity awareness training to all employees.

Establish and maintain a written business continuity plan to ensure operational resilience in the event of disruptions.

• Develop and Maintain a Business Continuity Plan - BCDR.A

  Create and regularly update a plan that enables the firm to continue operating or quickly recover from significant disruptions.

• Business Continuity Plan Development - BCDR.A.1

  Develop a comprehensive written business continuity plan identifying procedures for responding to emergencies and significant business disruptions.

• Data Backup and Recovery Procedures - BCDR.A.2

  Implement procedures for regular data backup and recovery of mission-critical systems and information.

• Alternate Communications Plan - BCDR.A.3

  Develop a plan for alternate communication methods between the firm customers and employees during a disruption.

Establish and maintain an AML program to prevent the firm from being used for money laundering or terrorist financing.

• Establish and Maintain an Anti-Money Laundering Program - AML.A

  Implement a program with policies procedures and controls designed to prevent detect and report money laundering activities.

• AML Program Development - AML.A.1

  Develop a written AML program that includes internal policies procedures and controls.

• Customer Identification Program (CIP) Implementation - AML.A.2

  Implement a Customer Identification Program to verify the identity of each customer.

• Suspicious Activity Reporting (SAR) Procedures - AML.A.3

  Establish procedures for identifying and reporting suspicious activity to the appropriate authorities.