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To speak to an account advisor,
call 312.676.1070 |
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Policy Statement
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The RCG Division of Marex Spectron ("RCG") recognizes that The International Money Laundering
Abatement and Anti-Terrorist Financing Act of 2001 ("Act") imposes important new
obligations on all financial firms for the detection, deterrence and reporting of
money laundering activities. Under the Act, money laundering is defined as any
financial transaction using income derived from criminal activity including, but not
limited to, drug trafficking, fraud, illegal gambling and terrorism. RCG has established
the following policies to ensure thorough compliance with all laws and regulations
regarding money laundering.
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Prior to the opening of any new account, RCG shall document the identity, nature
of business, income, source of assets, and investment objectives of each prospective
customer. Accounts for persons or entities from countries that do not cooperate
with the Financial Action Task Force (FATF) guidelines on money laundering shall be
subject to a heightened level of scrutiny. Accounts in the name of, or related to,
any person or entity on the Office of Foreign Asset Control (OFAC) Specially Designated
Nationals and Blocked Person list shall not permitted.
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On an ongoing basis, RCG shall review account activity for evidence of
suspicious transactions that may be indicative of money laundering activities.
This review may include surveillance of: 1) money flows into and out of
accounts, 2) the origin and destination of wire
transfers, 3) non-economic transactions, and 4) other
activity outside the normal course of business.
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Every officer, employee and associated person ("AP") of RCG
shall be responsible for assisting in the firm's efforts to uncover and report
any activity that might constitute, indicate or raise suspicions of money laundering.
To this end, RCG shall provide continuing education and training of all such persons.
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Should any officer, employee or AP of RCG have any knowledge, suspicions or information
regarding potential money laundering activities, that individual shall immediately notify
RCG's Compliance Department. RCG's Compliance Officer shall document the reported activity,
investigate fully, and, if warranted, report such activity to the senior management of RCG.
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RCG shall comply with all trade and economic sanctions imposed by OFAC against targeted
foreign countries and shall cooperate fully with government agencies,
self-regulatory organizations and law enforcement officials. As provided by the Act,
RCG may supply information about former, current or prospective customers to such bodies.
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Any officer, employee or AP who fails to comply with RCG's policies and procedures on
money laundering may be subject to disciplinary action, including termination of employment.
In addition, such failure may expose the individual to civil and criminal penalties under
the Act.
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