H.G.FASS, Inc. Corporate Policy on Compliance with the USA PATRIOT Act, Anti-Money Laundering (AML) Regulations, and Anti-Terrorism Measures.

 

1. Introduction

 

H.G.FASS, Inc. is committed to conducting our business in accordance with the highest ethical standards and complying with all applicable laws and regulations, including those related to the USA PATRIOT Act, Anti-Money Laundering (AML) regulations, and anti-terrorism measures. This policy outlines our commitment to preventing illegal activities, including money laundering and terrorism financing, and establishes compliance procedures to meet these important legal obligations.

 

2. Purpose

 

The purpose of this policy is to ensure that H.G.FASS, Inc. operates in compliance with the USA PATRIOT Act and AML regulations, thereby protecting our clients, employees, and the integrity of our business. Our aim is to prevent, detect, and report any suspicious activities that could be associated with money laundering and the financing of terrorism.

 

3. Compliance Officer

 

H.G.FASS, Inc. has designated a Compliance Officer responsible for overseeing the implementation and enforcement of this policy. The Compliance Officer will ensure that the company adheres to all applicable laws, regulations, and internal policies regarding AML and anti-terrorism compliance.

 

4. Customer Due Diligence (CDD)

 

As part of our compliance procedures, H.G.FASS, Inc. will:

 

Conduct thorough customer due diligence (CDD) to verify the identity of all clients BEFORE entering into any transactions.

This includes collecting and verifying information such as:

 

a. Full legal name

b. Date of birth

c. Address

d. Tax identification number or social security number

e. Government-issued identification (e.g., driver’s license or passport)

 

Establish and maintain a risk-based approach to assess and mitigate the risk associated with various customers based on their profile, transaction volume, and geographic location.

 

5. Monitoring and Reporting

 

H.G.FASS, Inc. will implement systems and controls to monitor customer transactions for suspicious activity. As part of our monitoring procedures, we will:

 

a. Regularly review client transactions for activities that may indicate money laundering or terrorism financing.

b. Maintain records of all transactions, as required by law, and retain these documents for a specified period.

c. Report any suspicious activity to the appropriate authorities in compliance with all regulations and law..

 

6. Employee Training

 

H.G.FASS, Inc. will provide ongoing training for all employees to ensure they are aware of their responsibilities related to AML compliance and anti-terrorism measures. The training program includes:

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a. An overview of the USA PATRIOT Act, AML regulations, and the importance of compliance.

b. Guidance on identifying and reporting suspicious activities.

c. Information on the legal consequences of failing to comply with AML and anti-terrorism regulations.

 

7. Recordkeeping

 

H.G.FASS, Inc. will maintain comprehensive records related to customer identification, transactions, and compliance efforts according to applicable legal requirements. These records will facilitate regulatory inquiries and audits and will be kept confidential.

 

8. Review and Revision of Policy

 

This policy will be reviewed annually and updated as necessary to ensure compliance with changing laws and regulations. H.G.FASS, Inc. remains committed to promoting a culture of compliance and integrity.

 

9. Complaint Procedure

 

If any employee or client identifies potential violations of this policy or has concerns about compliance, they are encouraged to report these issues directly to the Compliance Officer. Confidentiality will be maintained, and no retaliation will occur against anyone who reports in good faith.

 

10. Conclusion

 

H.G.FASS, Inc. is dedicated to preventing money laundering and terrorism financing in adherence to the USA PATRIOT Act and relevant AML regulations. By following this policy, we will secure our operations and protect our reputation in the precious metals industry.

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For any questions or concerns regarding this policy, please contact the Compliance Officer at hgf@hgfass.com.

 

Disclaimer: This policy is subject to change based on updates to regulations and best practices. It is the responsibility of all employees and clients to stay informed regarding compliance obligations.