Anti-Money Laundering (AML) Compliance Program
1. Firm Policy
The firm is unequivocally committed to prohibiting and actively preventing money laundering, as well as any activity that facilitates money laundering, terrorist funding, or criminal activities. This commitment aligns with all applicable requirements under the Bank Secrecy Act (BSA) and its implementing regulations.
Our AML policies, procedures, and internal controls are meticulously designed to ensure compliance with BSA regulations and FINRA rules. Regular reviews and updates will be conducted to accommodate changes in regulations and our business.
2. Providing AML Information
We commit to not disclosing that FinCEN has requested or obtained information from us, except as necessary to comply with the information request. The receipt of a National Security Letter (NSL) will be handled with utmost confidentiality. Any Suspicious Activity Report (SAR) filed after receiving an NSL will not reference the receipt or existence of the NSL, focusing only on the facts and circumstances of detected suspicious activity.
3. Monitoring Accounts for Suspicious Activity
We will vigilantly 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
Red flags signaling possible money laundering or terrorist financing include, but are not limited to:
Potential Red Flags in Customer Due Diligence and Interactions with Customers
1.The customer provides the firm with unusual or suspicious identification documents that cannot be readily verified or are inconsistent with other statements or documents.
2.The customer is reluctant or refuses to provide complete customer due diligence information.
3.The customer refuses to identify a legitimate source of funds or provides false, misleading, or substantially incorrect information.
4.The customer is domiciled in or transacts with counterparties in a jurisdiction known for bank secrecy, tax shelter, high-risk location, or conflict zone.
5.The customer has difficulty describing the nature of their business or lacks general knowledge of their industry.
6.The customer has been rejected or had their relationship terminated by other financial services firms.
7.The customer's legal or mailing address is associated with multiple other accounts or businesses that do not appear related.
8.The customer appears to be acting as a proxy for an undisclosed principal but is reluctant to provide information.
9.The customer is a trust, shell company, or private investment company reluctant to provide information on controlling parties and underlying beneficiaries.
10.The customer is publicly known or known to have criminal, civil, or regulatory proceedings against them.
11.The customer maintains multiple accounts with no apparent business purpose.
12.An account is opened in the name of a legal entity involved in activities related to a known terrorist entity.
Other Potential Red Flags
13.The customer exhibits unusual concern with the firm's compliance with government reporting requirements.
14.The customer tries to persuade an employee not to file required reports.
15.Law enforcement issues subpoenas or freeze letters regarding a customer or account.
16.The customer makes high-value transactions not commensurate with their known income.
17.The customer wishes to engage in transactions lacking business sense or an apparent investment strategy.
18.Securities transactions are unwound before maturity without apparent reason.
19.The customer does not exhibit concern with transaction costs.
4. AML Recordkeeping
The AML Compliance Person and their designee will ensure proper maintenance of AML records and the filing of SARs as required.
5. Clearing/Introducing Firm Relationships
We will collaborate closely with our clearing firm to detect money laundering. Information, records, data, and exception reports will be exchanged as necessary to comply with AML laws.
6. Senior Manager Approval
Senior management has provided written approval for this AML compliance program, considering it reasonably designed to achieve and monitor the firm's ongoing compliance with the requirements of the BSA and its implementing regulations.
Effective Date: January 1, 2022