Firewood Global Ltd (“FirewoodFX”) have adopted an Anti-Money Laundering (AML) compliance policy (“Policy”) as set forth in the Board minutes, dated 8 of June 2014.
This policy applies to all FirewoodFX officers, employees, appointed producers and products and services offered by FirewoodFX. All business units and locations within FirewoodFX will cooperate to create a cohesive effort in the fight against money laundering. Each business unit and location has implemented risk-based procedures reasonably expected to prevent, detect and cause the reporting of transactions. All efforts exerted will be documented and retained. The AML Compliance Committee is responsible for initiating Suspicious Activity Reports (“SARs”) or other required reporting to the appropriate law enforcement or regulatory agencies. Any contacts by law enforcement or regulatory agencies related to the Policy shall be directed to the AML Compliance Committee.
It is the policy of FirewoodFX to prohibit and actively pursue the prevention of money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. FirewoodFX is committed to AML compliance in accordance with applicable law and requires its officers, employees and appointed producers to adhere to these standards in preventing the use of its products and services for money laundering purposes.
For the purposes of the Policy, money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets.
Generally, money laundering occurs in three stages. Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s checks, or deposited into accounts at financial institutions. At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.
Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.
FirewoodFX has adopted a Customer Identification Program (CIP). FirewoodFX will provide notice that they will seek identification information; collect certain minimum customer identification information from each customer, record such information and the verification methods and results; and compare customer identification information with OFAC.
FirewoodFX will provide notice to customers that it is requesting information from them to verify their identities, as required by applicable law.
The following information will be collected for all new insurance and annuity applications:
Based on the risk, and to the extent reasonable and practicable, FirewoodFX will ensure that it has a reasonable belief of the true identity of its customers. In verifying customer identity, appointed producers shall review photo identification.
FirewoodFX shall not attempt to determine whether the document that the customer has provided for identification has been validly issued. For verification purposes, FirewoodFX shall rely on a government-issued identification to establish a customer’s identity. FirewoodFX, however, will analyze the information provided to determine if there are any logical inconsistencies in the information obtained.
FirewoodFX will document its verification, including all identifying information provided by the customer, the methods used and results of the verification, including but not limited to sign-off by the appointed producer of matching photo identification.
Transaction based monitoring will occur within the appropriate business units of FirewoodFX. Monitoring of specific transactions will include but is not limited to transactions aggregating $5,000 or more and those with respect to which FirewoodFX has a reason to suspect suspicious activity. All reports will be documented.
There are signs of suspicious activity that suggest money laundering. These are commonly referred to as “red flags.” If a red flag is detected, additional due diligence will be performed before proceeding with the transaction. If a reasonable explanation is not determined, the suspicious activity shall be reported to the AML Compliance Committee.
Examples of red flags are:
If the appointed producer:
Upon notification to the AML Compliance Committee an investigation will be commenced to determine if a report should be made to appropriate law enforcement or regulatory agencies. The investigation will include, but not necessarily be limited to, review of all available information, such as payment history, birth dates, and address. If the results of the investigation warrant, a recommendation will be made to the AML Compliance Committee to file a blocked assets and/or a SAR with the appropriate law enforcement or regulatory agency. The AML Compliance Committee is responsible for any notice or filing with law enforcement or regulatory agency.
Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know. Under no circumstances shall any officer, employee or appointed agent disclose or discuss any AML concern, investigation, notice or SAR filing with the person or persons subject of such, or any other person, including members of the officer’s, employee’s or appointed agent’s family.
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