Anti-Money Laundering Procedures
Purpose of the Anti-Money Laundering Rules and Compliance with the Office of Foreign Asset Control
In accordance wit the Patriot Act of 2001, Holland Financial Incorporated is required to screen transactions against the Office of Foreign Asset Control (OFAC) data base for Specially Designated Nationals (SDN).
Prospective and existing clients covenant with us to observe all Anti-Money Laundering and Exchange Control laws and regulations including economic and trade sanctions promulgated by the Office of Foreign Assets Control of the U.S. Department of Treasury in relation to any Financial Transaction or Funds Transfer, and those seeking to interact with our firm will use all reasonable endeavors to assist us to do likewise.
In particular, you covenant that the information given to us by you is accurate. We may disclose any information given to us that we in our sole discretion think necessary or desirable to disclose; except we will only disclose confidential information if required by law, a court, or legal, regulatory, or governmental authority, or as permitted by law in order to combat, prevent, or investigate issues arising under anti-money laundering laws, economic sanctions, or criminal law.
The purpose of the Anti-Money Laundering (AML) rules is to help detect and report suspicious activity including the predicate offenses to money laundering and terrorist financing, such as securities fraud and market manipulation. In order to ensure compliance with the Bank Secrecy Act, Holland Financial Incorporated is required to report suspicious activity by filing a Suspicious Activity Report with FINCEN (Financial Crimes Enforcement Network) with regard to an event occurring.
We will consider any transaction that appears to lack a reasonable economic basis or recognizable strategy as suspicious. This includes any pattern of transactions that deviates from the client’s normal pattern of activity or that is inconsistent with the client’s business. Such activities deserve close attention. Not all questionable activities are necessarily indications of money laundering, but they still may require further analysis.
As part of its due diligence, our firm will monitor activities that could indicate possible evidence of money laundering. In addition, Holland Financial Incorporated will take the following measures:
- Implement procedures to reasonably detect and report suspicious activity.
- Utilize and monitor a risk-based customer identification program.
- Conduct periodic reviews to ensure proper implementation of AML Procedures.
- Participate in biennial training and education regarding AML regulation.
If you, or your authorized representative, breach any such laws or regulations, you irrevocably agree that we may retain any monies or funds transmitted to us pursuant to our compliance with the U.S. Department of Treasury and/or not fulfill any Funds Transfer Request or Financial Transaction if we are required to take or refrain from such action by any legal, regulatory, or governmental authority or if we reasonably believe that such action may violate any laws or regulations described herein, and such monies shall not bear interest against us. You further agree that we may pay such monies to the appropriate legal, regulatory, or governmental authority, if and when required by law.
Any Funds Transfer Service, Financial Transactions, as well these terms and conditions shall be governed by the internal laws of the State of Wisconsin without regard to its conflicts of rules and the laws of the United States.