Anti Money Laundering

This is our Anti Money Laundering Policy, put in place and described here to help Competent Authorities preventing the act of money laundering, and to prevent, unknowingly, participating or being the victim of money laundering.

It is the policy of the firm to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the Patriot Act and Homeland Security and its implementing regulations.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have 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.

To all of our affiliates be aware when uncommon transactions take place; Payment Methods Involving large amounts of cash, multiple and/or consecutive Money Orders, Checks of any kind, traveler’s checks, personal, cashier’s or third party checks. Watch out for: Customers who are unwilling to provide you with their complete information, including showing a valid ID and providing you with their thumb print. Any practice that seems odd or suspicions should be considered. Monitored and consulted with proper authorities.

Any Transaction over $10,000.00 concerning Precious Metals and/or Diamonds in any form or shape is to be reported to the IRS using the FORM 8300.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.

Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable JVC regulations and FINRA rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.