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The Company protects itself from involvement in money laundering or suspicious activity by the following means:

  • Performing an enterprise-wide risk assessment to determine the risk profile of the Company
  • Establishing AML policies and procedures
  • Implementing internal controls throughout its operations that are designed to mitigate risks of money laundering
  • Performing know your customer (“KYC”) procedures on all Clients
  • Designating a Compliance Officer with full responsibility for the AML Program
  • Conducting frequent AML audits through auditors appointed by the the Financial Services Standards Association (VQF).
  • Providing AML training to all employees


The Policy will be approved by the Company’s Board. The Policy once approved will be provided to all employees. Each employee will acknowledge the Policy in writing. All policies and procedures will be reviewed and updated or revised as needed, but no less often than annually.


The Company has developed and implemented internal controls for the purpose of ensuring that all of its operations comply with all AML legal requirements and that all required reports are made on a timely basis. Some of those internal controls are listed within this document and include, but are not limited to, the Customer Identification Program, the Suspicious Activity Reporting system, and the required reports on the Program’s effectiveness to the Board.


All of the officers and employees of the Company are required to receive AML training according to stipulations from the Financial Services Standards Association (VQF) and the Eidgenössischen Finanzmarktaufsicht” (The Swiss Financial Supervisory Authority – FINMA).

The Company will track the training progress of all employees and maintain documentation of each employee, the date of the AML training as well as a description of such training. New employees will receive appropriate AML training within 30 days of their hire date. Training for all employees will include not only the legal elements of AML laws and regulations but will also cover job specific applications of these laws. Ongoing training will be provided and updated regularly to reflect current developments and changes to laws and regulations.


The Company has appointed a Compliance Officer to be responsible for the management, coordination and monitoring of compliance with this policy and all applicable AML laws and regulations. The Compliance Officer will have a working knowledge of all AML laws and be qualified by knowledge, experience and training. The Compliance Officer will be responsible for filing (if applicable) or keeping a record of suspicious transaction reports (“STR”) and suspicious activity reports (“SAR”) with the appropriate agencies and for overseeing the annual audit. The Compliance Officer will oversee all corrective action of any audit findings or other AML-related issues. The Compliance Officer will be responsible for all record keeping requirements and provide reports on the effectiveness of the AML program to the Company’s Board.


It is the Company’s policy to ensure that it has reasonably identified each customer who trades with the Company. Clients may be identified using a variety of methods.


Additionally, the Company will, as part of its account-opening

  1. cross-check the names of board members, shareholders and beneficial owners of clients against compliance databases such as the OFAC Specially Designated Nationals list and other governmental watch lists
  2. require clients and their respective board members, shareholders and beneficial owners to provide proof of identification; and
  3. not permit any trades to be made with incomplete account-opening information.


  • Business name
  • Name of businesses representative(s) for the account
  • The address of the customer’s principal place of business and, if different, the customer’s mailing address. If the customer has a local address different from its principal place of business, the local address.
  • Official issued identification number of the principal(s) involved with the account (e.g., passport number, social security number, employee identification number or individual taxpayer identification number)
  • Copy of valid photo identification of the principal(s) involved with the account (e.g., drivers license, armed forces identification, passport, alien identification card)

Customer due diligence procedures will be followed to determine the beneficial owners of corporate or trust accounts. This would include determining if the customer is an agent of or on behalf of another; obtaining information about the structure or ownership of a customer who is a legal entity that is not publicly traded in the US; and where the customer is a trustee, obtaining information about the trust structure, determining the provider of the funds and any persons who have control over the funds or the power to remove and/or influence the trustee.


Documents used in opening an account relationship must be verified prior to establishing the account. Verification of identity will require multi-factor authentication, layered security and other controls to ensure a meaningful client identity confirmation process based on account size or other factors.

  • The following are examples of verification methods the Company may use:
  • Obtaining proof of address, such as a copy of a utility bill or bank statement from the account holder, or receiving back documents mailed to the client’s address.
  • Having a telephone call or skype conversation after the account relationship is open.
  • Obtaining financial statements or auditors’ reports.
  • Comparing the identifying information with information available from a trusted third party source, such as a credit report from corporate credit rating agencies like Dun & Bradstreet, Equifax, Esperian, Infogroup, etc.

Analyzing whether there is logical consistency between the identifying information provided, such as the customer’s name, street address, ZIP code, telephone number and date of birth (logical verification).

  • Utilizing knowledge-based challenge questions.
  • Utilizing complex device identification (such as “digital fingerprints” or geo-location checks).
  • Obtaining a notarized copy of an individual’s birth certificate or a business’ certificate of incorporation sealed with an apostille for valid identification .

When the type of account increases the risk that the Company will not be able to verify the true identity of the customer through documents is confirmed the account will be closed.


The Company will diligently monitor transactions for suspicious activity. Transactions that are unusual will be carefully reviewed to determine if it appears that they make no apparent sense or appear to be for an unlawful purpose. Internal controls will be implemented so that an ongoing monitoring system is in place to detect such activity as it occurs. When such suspicious activity is detected, the Compliance Officer will determine whether a filing with any law enforcement authority is necessary.

Suspicious activity can include more than just suspected money laundering attempts. Activity may be suspicious, and the Company may wish to make a filing with a law enforcement authority, even if no money is lost as a result of the transaction.

The Compliance Officer will initially make the decision of whether a transaction is potentially suspicious. Once the Compliance Officer has finished his review of the transaction details, he or she will consult with the Company’s senior management to make the decision as to whether the transaction meets the definition of suspicious transaction or activity and whether any filings with law enforcement authorities should be filed.

The Compliance Officer will maintain a copy of the filing as well as all back up documentation. The fact that a filing has been made is confidential. No one, other than those involved in the investigation and reporting should be told of its existence. In no event should the parties involved in the suspicious activity be told of the filing. The Compliance Officer may inform the Company’s Board of the filing and the underlying transaction.


Reasonable procedures for maintaining records of the information used to verify a person’s name; address and other identifying information are required under this Policy. The following are required steps in the record keeping process:

  • The Company is required to maintain a record of identifying information provided by the customer.
  • Where the Company relies upon a document to verify identity, the Company must maintain a copy of the document that the Company relied on that clearly evidences the type of document and any identifying information it may contain.
  • The Company must also record the methods and result of any additional measures undertaken to verify the identity of the customer.
  • The Company must record the resolution of any discrepancy in the identifying information obtained.
  • All transaction and identification records will be maintained for a minimum period of five years.


The Compliance Officer is responsible for directing any AML audit of the Company’s operations and respond to any requests from the Financial Services Standards Association (VQF), the „Eidgenössische Finanzmarktaufsicht” (The Swiss Financial Supervisory Authority – FINMA) or any other Swiss government authorities.

The audit will be conducted by an independent third party appointed by the Financial Services Standards Association (VQF). The Compliance Officer will develop corrective action plans for all issues that are raised in the audit and will provide the audit report and all corrective action plans to the Company’s senior management for review. Reports of the corrective action will continue until all are resolved.