money laundering prevention.

Anti Money Laundering (AML) Policy

Our AML policy is designed to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of criminal activities.


The AML Program

The CCO shall:

  • Monitor the firm’s compliance with this policy;

  • Monitor changes in applicable laws and regulations relating to money laundering and implement further controls as may be required by such changes in laws and regulations;

  • Ensure the firm keeps the records required by this policy;

  • Ensure Suspicious Activity Reports (SAR-SFs) are filed when required by applicable law and regulations; and

  • Communicate with employees of the firm to ensure compliance with this policy.


Client Identification and Verification

Prior to establishing a new client relationship, we must obtain and review the following information to verify the identity of the client:

  • The client’s legal name;

  • The client’s date of birth (if the client is an individual);

  • The client’s physical address (not a P.O. Box or email address);

  • The client’s telephone number;

  • The client’s government identification number, or SSN.

  • A short description of the client’s primary business, if any; and

  • A short description of the client’s primary source of funds (e.g., business listed above, inheritance, pension).

This information is collected as part of the process of establishing client accounts and is required information for all such accounts. By proxy, details such as government ID and or Social Security number may be collected at the time of application by the custodian knowing that no account will be opened without these details.


Clients Who Refuse to Provide Information

Simple, don't open the account.

If a potential or existing client either refuses to provide the information described above or appears to have intentionally provided misleading information, we will not open a new account and, after considering the risks involved, consider closing any existing account.

In either case, the firm CCO must be notified so that we can determine whether we should file a Form SAR-SF.

Verifying Information

We must ensure that we have a reasonable belief that we know the true identity of our clients by using risk-based procedures to verify and document the accuracy of the information we receives about our clients.

In verifying client identity, we will analyze any logical inconsistencies in the information we obtain.

If we detect any red flags that indicate possible money laundering, criminal, or terrorist financing activity, we will, after internal consultation with the firm's CCO, file a SAR-SF in accordance with applicable law and regulation.


Lack of Verification

When we cannot form a reasonable belief that we know the true identity of a client, we will do the following:

  • (1) not open an account;

  • (2) impose terms under which a client may conduct transactions while we attempt to verify the client’s identity;

  • (3) close an account after attempts to verify client’s identity fail; or

  • (4) file a SAR-SF if required by applicable law and regulation.


Recordkeeping

Core Planning will document any identifying information provided by a client and the resolution of any discrepancy in the identifying information.

The firm will keep records containing a description of any document that it relied on to verify a client’s identity, noting the type of document, any identification number contained in the document, the place of issuance, and if any, the date of issuance and expiration date.

In practice, if a government ID is used as an identifying document, an image of that ID will suffice.

With respect to non-documentary verification, the firm will retain documents that describe the methods and the results of any measures it took to verify the identity of a client and will maintain records of identification information for five years after the account has been closed; it will retain records made about verification of the client's identity for five years after the record is made.

Responding to Red Flags

When a member of the firm detects a red flag with respect to a client account, he or she will investigate further under the direction of the CCO. This may include gathering additional information internally or from third-party sources, contacting the government or filing a Form SAR-SF.


Money laundering “red flags” include:

  • The client exhibits unusual concern about the firm's compliance with government reporting requirements and the firm's AML policies (particularly concerning his or her identity, type of business and assets), or is reluctant or refuses to reveal any information concerning business activities, or furnishes unusual or suspicious identification or business documents;

  • The client wishes to engage in transactions that lack business sense or apparent investment strategy, or are inconsistent with the client's stated business or investment strategy;

  • The information provided by the client that identifies a legitimate source for funds is false, misleading, or substantially incorrect;

  • Upon request, the client refuses to identify or fails to indicate any legitimate source for his or her funds and other assets;

  • The client has a questionable background or is the subject of news reports indicating possible criminal, civil, or regulatory violations;

  • The client exhibits a lack of concern regarding risks, commissions, or other transaction costs;

  • The client appears to be acting as an agent for an undisclosed principal, but declines or is reluctant, without legitimate commercial reasons, to provide information or is otherwise evasive regarding that person or entity;

  • The client has difficulty describing the nature of his or her business or lacks general knowledge of his or her industry;

  • The client attempts to make frequent or large deposits of currency, insists on dealing only in cash, or asks for exemptions from the firm's policies relating to the deposit of cash;

  • The client engages in transactions involving cash or cash equivalents or other monetary instruments that appear to be structured to avoid the $10,000 government reporting requirements, especially if the cash or monetary instruments are in an amount just below reporting or recording thresholds;

  • For no apparent reason, the client has multiple accounts under a single name or multiple names, with a large number of inter-account or third-party transfers;

  • The client's account has unexplained or sudden extensive wire activity, especially in accounts that had little or no previous activity;

  • The client's account shows numerous currency or cashier’s check transactions aggregating to significant sums;

  • The client's account has a large number of wire transfers to unrelated third parties inconsistent with the client's legitimate business purpose;

  • The client's account indicates large or frequent wire transfers, immediately withdrawn by check or debit card without any apparent business purpose;

  • The client makes a funds deposit followed by an immediate request that the money be wired out or transferred to a third party, or to another firm, without any apparent business purpose;

  • The client makes a funds deposit for the purpose of purchasing a long-term investment followed shortly thereafter by a request to liquidate the position and transfer of the proceeds out of the account;

  • The client requests that a transaction be processed to avoid the firm's normal documentation requirements;

  • The client, for no apparent reason or in conjunction with other red flags, engages in transactions involving certain types of securities, such as penny stocks, Regulation S stocks, and bearer bonds, which although legitimate, have been used in connection with fraudulent schemes and money laundering activity (such transactions may warrant further due diligence to ensure the legitimacy of the client's activity);

  • The client's account shows an unexplained high level of account activity with very low levels of securities transactions;

  • The client maintains multiple accounts, or maintains accounts in the names of family members or corporate entities, for no apparent purpose; or

  • The client's account has inflows of funds or other assets well beyond the known income or resources of the client.

Responsibility for AML Records and SAR Filing

Core Planning’s CCO will be responsible for ensuring that AML records are maintained properly and that SARs are filed as required.

The firm will maintain AML records and their accompanying documentation for at least five years.


Training Programs

The CCO will develop and conduct ongoing employee training.

This training will occur on at least an annual basis or when material changes occur to the AML policy and procedures. The firm will maintain records to show the persons trained, the dates of training, and the subject matter of their training.


Training will include, at a minimum:

  • how to identify red flags and signs of money laundering that arise during the course of the employees’ duties;

  • what to do once the risk is identified;

  • what employees' roles are in the firm's compliance efforts and how to perform them;

  • the firm's record retention policy;

  • and the disciplinary consequences (including civil and criminal penalties) for non-compliance with the PATRIOT Act.