An effective anti-money laundering compliance program must include “know your customer” procedures. Information must be provided to learn the true identity of the customer, the nature of the customer’s business, and the intended purpose of the customer’s transactions.
As broker, TP GLOBAL FX shall be responsible for:
Each trading account applicant must first be approved and accepted by the broker before funding the trading account and trading.
Un Sanction List
All individuals and entities will be checked against applicable lists of sanctioned countries published by the United Nations and periodically rechecked against updated lists. If a customer is from a country on the list, his or her account will not be opened.
All new customers’ names will be compared to the list provided by our third-party customer screening service such as COMPLINET. If a customer’s name appears on the list, we will contact low enforcement authority immediately.
Suspicious transactions are those that have no business or apparent lawful purpose, are unusual for the customer, or lack any reasonable explanation.
A few examples of “red flags” are:
For all accounts, a determination of whether any transaction or series of transactions is suspicious will depend on the customer and the particular transaction(s) compared with the customer’s normal business activity. All accounts will be monitored for suspicious activity every 30 days.
We do not accept third party funds. Also, incoming and outgoing bank wires must be to the same banking institution having the customer’s name on the account.
Customer Identification Program
Financial Services Companies must ascertain the identity of their customers, learn the nature of the customer’s business and learn the intended purpose of customers’ transactions.
The Company’s anti-money laundering procedures mandate that individuals and entities that refuse to provide information verifying their identities, will not be permitted to open accounts at TP GLOBAL FX.
All new accounts will be subject to the stringent approval process by “COMPLIANCE”. “COMPLIANCE” will ensure that the new account form is complete. “COMPLIANCE” will review all new accounts for financial credit worthiness and trading suitability purposes. However, he will also review for anti-money laundering purposes. “COMPLIANCE” will check to ensure that identifying information is listed for all individuals named on the new account form and that none of the individuals named on the third party customer screening service list or any other watch lists are opened at the Company.
The stated purpose of customers in placing funds with us is set forth in our customer agreement, to wit: speculation in foreign currencies. Any conduct or account activity that is inconsistent with trading foreign currencies with a goal of profiting thereby, must be considered suspicious activity and reported immediately to “COMPLIANCE” who will evaluate the situation and determine whether to take further action consistent with these procedures.
We may consider the following factors, among others, in assessing the risks of violating Anti-Money Laundering Policies posed by particular customers or transactions:
If it is determined to accept a foreign customer account where the country of residence is listed on UN’s list of non-cooperative countries or UN’s list of sanctioned countries, additional monitoring of the customer’s trading and cash activity will be conducted by “COMPLIANCE”. He will review, in detail, all transactions and cash activity by examining the monthly account statements to ensure that none of the “red flags” set forth in the Wire Activity and Management Review Sections below should be raised.
Subject to the Company’s own assessment of any additional due diligence necessary to assess risk, the following procedures are ordinarily appropriate for the following types of accounts:
We will be verifying all information given pertaining to business and source of income of a customer. We will not be opening correspondent accounts. We do not open private banking accounts.
For each new customer, who is an individual, we will collect:
For each new customer which is an entity, we will collect:
We will not accept an account without the required identification information. If the entity is a trust or similar, personal identification information as outlined in the previous paragraph will be needed for the account controller.
In the event a customer does not present a valid government ID; or the firm is not familiar with the documents the customer provides; or the customer opens the account without appearing in person; and any other circumstances that increase the risk that we will not be able to verify the true identity of the customer through documents an account will not be opened.
We will be verifying all information given pertaining to the purpose of the trading account.
Although not all inclusive, some examples of behaviour that should cause concern at the account opening stage are:
As part of the requirement to open account, the Company will obtain information sufficient to ascertain the identity of the corporate or business entity opening the account and the authority of the business representative to act on the corporation’s or entity’s behalf. This information will also be checked against existing lists and current databases. The type of documentation obtained by Company may vary depending upon the nature of the corporate or business entity. Accounts that lack this information may not be permitted to continue to do business with the Company. Below is the basic information we require: