Anti Money Laundering (AML) and Know Your Customer
(KYC) Policy
It is the Policy of PinaTradeX LLC and its affiliates (hereinafter
referred to as “the Company”) 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. The
Company requires its officers, employees, and affiliates to adhere to
these standards in preventing the use of its products and services for
money laundering purposes.
For the purposes of this 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.
Each employee of the Company, whose duties are associated with the
provision of products and services of the Company and who directly or
indirectly deals with the clientele of the Company, is expected to know
the requirements of the applicable laws and regulations which affect his
or her job responsibilities, and it shall be the affirmative duty of
such employee to carry out these responsibilities at all times in a
manner that complies with the requirements of the relevant laws and
regulations.
The laws and regulations include, but not limited to: “Customer Due
Diligence for Banks” (2001) and “General Guide to Account Opening and
Customer Identification” (2003) of Basel Committee on Banking
Supervision, Forty + nine Recommendations for Money Laundering of FATF,
USA Patriot Act (2001), Prevention and Suppression of Money Laundering
Activities Law (1996).
To ensure that this general policy is carried out, management of the
Company has established and maintains an ongoing program for the purpose
of assuring compliance with the relevant laws and regulations and the
prevention of money laundering. This program seeks to coordinate the
specific regulatory requirements throughout the group within a
consolidated framework in order to effectively manage the group’s risk
of exposure to money laundering and terrorist financing across all
business units, functions, and legal entities.
Each of the affiliates of the Company is required to comply with AML and
KYC policies.
All identification documents and services records shall be kept for the
minimum period of time required by local law.
All new employees shall receive anti money laundering training as part
of the mandatory new-hire training program. All applicable employees are
also required to complete AML and KYC training annually. Participation
in additional targeted training programs is required for all employees
with day-to-day AML and KYC responsibilities.
