* This policy of Wealthfronttradingplatform inc (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. Company requires its officers, employees and affiliates to adhere
to these standards in preventing
the use of Company’s Services for money laundering purposes.
* 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.
* Client guarantees a legal origin, legal ownership and availability at Client of the
actual right to use of the money
transferred by Client to Client’s Account.
* 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.
* Each employee of Company, whose duties are associated with the provision of products
and services of Company and who
directly or indirectly deals with Client of Company, is expected to know the
requirements of the applicable laws and
regulations which affect Client’s 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.
* To ensure that this general policy is carried out, management of 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.
* 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.
* All identification documentation and services records shall be kept for the minimum
period of time required by local
law
* Each of the Company’s affiliates is required to comply with AML and KYC policies.