The guidance clarifies the CIP and BO requirements applicable to introducing brokers (IBs) under the Bank Secrecy Act (BSA). The guidance provides regulatory clarity to certain IBs who lack access to the information needed to comply with CIP and BO obligations. The guidance eliminates duplicative efforts without impacting money laundering or terrorist financing risk, as the customer due diligence obligations will continue to be performed by the futures commission merchant (FCM) that carries the customer account.