The purpose of the AML compliance plan is to establish the general framework for the fight against money laundering, terrorism, corruption and other financial crimes.
Endeavor Metals Group LLC is committed to reviewing the AML strategies and objectives on an ongoing basis and to maintaining an effective AML program. We are committed to high standards of AML compliance and require management, employees, and agents to adhere to these standards in preventing the use of our products and services for money laundering purposes.
Adherence to this policy is absolutely fundamental for ensuring that we comply with applicable anti-money laundering legislation. We are required and committed to adhere to minimum standards of anti-money laundering compliance based on the applicable anti-money laundering laws and regulations and any additional standards from our regulatory supervisors which clarify the main statutory duties imposed on our institution.
A key component of an effective compliance program is employee training. Minimum training must include how to identify suspicious activity and structured transactions, record keeping, recording, and reporting requirements, verifying identification, and familiarity with anti-money laundering statutes.
All employees should be required to read this manual and sign a copy of the Acknowledgement of Employee Training that will be retained in their personnel file or Anti-Money laundering files.
Money laundering is defined as “the attempt to conceal or disguise the nature, location, source, ownership, or control of illegally obtained money.”
There are 3 stages of money laundering. By using these stages a person can make illegal funds appear to come from a legal or legitimate source.
A person purchases money orders, traveler’s checks, prepaid cards, and money transfers, etc. with the funds from a crime.
A person moves money from one financial institution to another and changes the form of the money through multiple transactions making it hard to trace the money to its original source.
Changing the money into a seemingly legitimate form. (purchasing automobiles, businesses, real estate, etc.) that can later be sold.
OFAC is part of the U.S. Department of the Treasury and is responsible for enforcing U.S. government sanctions against countries, organizations and individuals. Sanctions programs normally involve blocking assets to further national security. Many sanctioned individuals (SDN’s) are known drug dealers and terrorists. All U.S. entities are prohibited from doing financial transactions with the SDN’s. A list of names of individuals is available on the U.S. Department of the Treasury website. www.ustreas.gov/offices/enforcement/ofac.
Employees shall be trained to identify transactions that may involve use of the dealer to facilitate money laundering or terrorist financing, including, but not limited to, transactions that involve:
Employees shall do all of the following:
Endeavor Metals Group LLC shall at all times cooperate with and take guidance from the Financial Crimes Enforcement Network, United States Department of Treasury; the Internal Revenue Service; and other appropriate regulatory and enforcement agencies.
Endeavor Metals Group agrees to formally designate a competent individual to serve as its Compliance Officer. The designated employee should be in a position of responsibility that allows them to implement an effective Anti-Money Laundering Compliance Program.
The Compliance Officer, along with senior management, is responsible for ensuring the ongoing compliance with all federal and state anti-money laundering laws and regulations.
The Compliance Officer’s duties will include: ensuring the anti-money laundering program is implemented effectively; ensuring that the anti-money laundering program is updated as necessary to reflect changes in the risk assessment, statutory requirements, and further guidance issued by the Department of the Treasury; and ensuring that appropriate personnel are trained in accordance with the policy.
The Compliance Officer is also responsible for ensuring that a periodic review is conducted on the quality of the Compliance Program. This review may not be conducted by the Compliance Officer. The review should be done by a senior level employee or qualified professional who understands the requirements of an effective compliance plan.