1. Firm Policy
It is the policy of the firm to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities.
2. Giving AML Information to Applicable Authority
We will respond to an applicable authority’s request concerning accounts and transactions by immediately searching our records to determine whether we maintain or have maintained any account for, or have engaged in any transaction with, each individual. We do not have entity or organization account.
3. Prohibited Countries List
In our website, we declare we do not provide the service to the client of Iran, Sudan, North Korea, Syria or any other country listed on UN or U.S. sanction list.
4. Monitoring Accounts for Suspicious Activity
We will monitor account activity for unusual size, volume, pattern or type of transactions, taking into account risk factors and red flags that are appropriate to our business. (Red flags are identified below.)
a. Red Flags
Red flags that signal possible money laundering or terrorist financing include, but are not limited to:
- Activity that is unexplained, repetitive, unusually large or shows unusual patterns or with no apparent business purpose.
- Unexplained high level of account activity with very low levels of securities transactions.
b. Responding to Red Flags and Suspicious Activity
When an employee of the firm detects any red flag, or other activity that may be suspicious, he or she will notify. The firm will determine whether or not and how to further investigate the matter. This may include gathering additional information internally or from third-party sources, freezing the account and/or contacting the government.
5. AML Recordkeeping
In addition, as part of our AML program, our firm will create and maintain relevant documentation on customer identity and verification and funds transmittals and their accompanying documentation for at least five years.
6. Training Programs
Our training will occur on at least an annual basis. It will be based on our firm’s size, its customer base, and its resources and be updated as necessary to reflect any new developments in the law.
Our training will include, at a minimum: (1) how to identify red flags and signs of money laundering that arise during the course of the employees’ duties; (2) what to do once the risk is identified (including how, when and to whom to escalate unusual customer activity or other red flags for analysis); (3) what employees' roles are in the firm's compliance efforts and how to perform them; (4) the firm's record retention policy; and (5) the disciplinary consequences (including civil and criminal penalties) for non-compliance with the AML.
We will develop training in our firm, or contract for it. Delivery of the training may include educational pamphlets, videos, intranet systems, in-person lectures and explanatory memos.
We will review our operations to see if certain employees, such as those in compliance, margin and corporate security, require specialized additional training. Our written procedures will be updated to reflect any such changes.
7. Monitoring Employee Conduct and Accounts
We will subject employee accounts to the same AML procedures as customer accounts. We will also review the AML performance of supervisors, as part of their annual performance review.
8. Confidential Reporting of AML Non-Compliance
Employees will promptly report any potential violations of the firm’s AML compliance program to the CEO. Such reports will be confidential, and the employee will suffer no retaliation for making them.