Anti-Money Laundering Plan
Quality Silver Bullion Anti-Money Laundering Policy
Policy Statement
Quality Silver Bullion is a legal, ethical and transparent company, and it takes the responsibility to ensure and maintain that its assets and resources are not being used for corruption, irregularities, or money laundering. The company has taken it upon itself to detect frauds, irregularities, abuse of position, and institutional gains.
Purpose
The purpose of this policy is to make sure that the company’s financial processes and procedures are according to the anti-money laundering laws.
Scope
This policy applies to every entity related to Quality Silver Bullion and its employees, directors, officers, contractors, or any third party working on behalf of the company.
The policy is for internal use, and the administration is required to convey it to every concerned person or entity. Failure to comply with the policy will result in appropriate action.
Money Laundering
Money laundering refers to those assets that are money that is acquired in exchange for money or assets gained unlawfully. It also includes money spent for terror purposes, regardless of the means it was obtained.
Under this policy, money earned by using the following means is considered money laundering, and it is prohibited;
- Money or assets received in exchange for criminal or unlawful acts. Money whose origin is not explicit or earned by assisting any activity in evading lawful means.
- Property gained after any criminal activity and its origin, location, and disposition are not transparent.
- Property which is promoting any unlawful activity
- Terrorism financing
Responding to Red Flags and Suspicious Activity
When a member of Quality Silver Bullion detects any red flag, he or she will investigate further under the direction of the AML Compliance Officer. This may include gathering additional information internally or from third-party sources, contacting the government or filing a Form Suspicious Activity Report (SAR). The (Covenant Partner) is obligated to report suspicious transactions that are conducted or attempted by any potential customer We recognize that transactions are reportable under 31 U.S.C. 5318(g) regardless of whether they involve currency. SAR reports will be filed no later than 30 days after initial detection.
Quality Silver Bullion is provided with the same “safe harbor” as provided for other financial institutions protecting lenders and their employees recognizing they must feel free to report suspicious transactions, and to share information in the employment context about individuals involved in misconduct, without fear of liability.
Currency Transaction Reports (CTR) – $10,000 Threshold
Quality Silver Bullion covenant partners must file a report with the Internal Revenue Service within 15 days of receiving currency of more than $10,000 in one transaction, or in two or more related transactions occurring in a 12 month period. The term “currency” includes coins and paper money, cashier’s checks, money orders, bank drafts and traveler’s checks. It does not include personal checks. Contrary to the SAR confidentially requirements, anyone involved in the transaction must be notified with a written statement that a report is being filed. The form IRS Form 8300 can be found here: http://www.irs.gov/pub/irs-pdf/f8300.pdf
Red Flags:
Red Flags that signal possible money laundering include but are not limited to:
• The customer exhibits unusual concern regarding the Company’s compliance with
government reporting requirements and the Company’s AML policies, particularly with
respect to his or her identity, type of business and assets, or is reluctant or refuses to
reveal any information concerning business activities, or furnishes unusual or suspect
identification or business documents.
• The customer attempts to make frequent or large deposits of currency, insists on
dealing only in cash equivalents, or asks for exemptions from the Company’s policies
relating to the deposit of cash and cash equivalents.
• The customer engages in transactions involving cash or cash equivalents or other
monetary instruments that appear to be structured to avoid the $10,000 government
reporting requirements, especially if the cash or monetary instruments are in an amount
just below reporting or recording thresholds.
• The customer’s account shows numerous cash equivalent transactions aggregating to
significant sums.
• The customer requests that a transaction be processed in such a manner to avoid the
company’s normal documentation requirements.
AML Compliance Officer Designation and Duties
As required under the USA Patriot Act of 2001 (PATRIOT Act), Quality Silver Bullion designates James Little as the Anti-Money Laundering Program Compliance Officer, with full responsibility for Quality Silver Bullion‘s anti-money laundering (AML) program. The AMLCO will ensure:
- Quality Silver Bullion’s AML Program is implemented effectively, including monitoring compliance by Quality Silver Bullion’s officers and employees with their obligations under the program;
- The AML Program is updated, as necessary; and,
- Appropriate persons are educated and properly trained.
The company must consult with the legal department before embarking on business with a third party and carefully screen such interactions.
The policy is subject to updates and amendments, which will be communicated to the stakeholder immediately.
Approved by:
James Little