Comment from OTC Markets Group
OTC Markets GroupSupportBusiness
Summary: OTC Markets Group supports the modernization of AML/CFT programs but requests that FinCEN clarify that "utility ATSs" should be subject to narrowly tailored requirements. They argue that because these entities do not hold customer accounts or funds, they should not be burdened with customer-level AML obligations that are structurally impossible for them to perform and are already handled by broker-dealer subscribers.
Please see comments attached.