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Fire Proof Silver LLC

Anti-Money Laundering Policy
Updated Policy – Effective Aug 27th 2018

The owners of Fire Proof Silver, LLC are committed to combating money laundering. Company owners will actively search for suspicious activity. When it is discovered, an owner will review it and determine as to whether a Suspicious Activity Report (SAR) should be filed.

 

The owner will have ten (10) business days to conduct the review and make recommendation to the other Co-owner. All actions will be made in writing and forwarded to the other business owner. The owners are responsible for reviewing and determining if an SAR should be filed.

 

The owner will file the SAR with the appropriate legal and regulatory authorities to include the Lacey Police Department and if/as needed other appropriate geographically impacting police departments or agencies. All supporting evidence for the SAR will be maintained for a minimum of five (5) years, and will be securely stored. The owners will store all applicable documentation and if/as relevant the dollar amount of the suspicious activities and why they were deemed that way. If and when precious metals are involved detailed records of types and amounts shall be including as part of file.

 

Fire Proof Silver, LLC meets the definition of a “Nonbank Financial Institution and nonfinancial business (NBFI). Fire Proof Silver does not have employees and the 2 owners (Brandon LeMay and Annabelle LeMay) are responsible for all business activity. Brandon LeMay is the primary business manager and will assume the function and title of the Anti-money Laundering Enforcement Officer responsible (also referred to as “AML compliance Officer”) for reporting any and all suspicious activity and will complete and file any SAR if/as needed. 

 

Fire Proof Silver LLC, will comply and cooperate with any/all legally recognized authorities to include Financial Crimes Enforcement Network (FinCEN) requests with or without warrant to the full extent of the law.

 

In any such event of suspicious activity or need to report activity owners shall review, refer and comply with all sections contained and outline within “31 CFR 1027.210 – Anti-money laundering programs for dealers in precious metals, precious stones, or jewels.”

Fire Proof Silver has two definitions for money laundering:

 

  • It is the introduction of illegally obtained currency into the budget or business financial system.

  • It is using the business financial system to illegally hide currency that was lawfully obtained.

 

It is not hard for criminals to obtain currency. However, until the currency is deposited into the banking system, their ability to utilize it is restricted. When banks, or businesses, knowingly accept the cash deposits from criminals, they legitimize (or launder) the proceeds. Accordingly, criminals must do business with banks. Businesses like Fire Proof Silver must be diligent in detecting and reporting suspicious activity.

 

It is impossible for any policy to define all activity that would qualify as suspicious. However, the following guidelines quantify the types of suspicious activities that Fire Proof Silver. LLC will monitor for.

 

  1. One or more cash deposits a week, that are structured avoid CTR reporting.
  2. Two or more instances a week, where a customer makes two or more cash purchases on the same day, and the total of the deposits is between $5,000 and $8,000.
  3. One or more instances a week, where a customer has made cash purchase to two or more related accounts, and the total of the deposits is between $5,000 and $10,000.
  4. Any potential or suspect that any person is trying to sell or trade stolen materials. (namely precious metals)

Additionally more specific and pursuant to 31 CFR 1027.210

Fire Proof Silver owners shall implement action in the following circumstances or behaviors observed from any persons identified…

(A) Unusual payment methods, such as the use of large amounts of cash, multiple or sequentially numbered money orders, traveler’s checks, or cashier’s checks, or payment from third parties;

(B) Unwillingness by a customer or supplier to provide complete or accurate contact information, financial references, or business affiliations;

(C) Attempts by a customer or supplier to maintain an unusual degree of secrecy with respect to the transaction, such as a request that normal business records not be kept;

(D) Purchases or sales that are unusual for the particular customer or supplier, or type of customer or supplier; and

(E) Purchases or sales that are not in conformity with standard industry practice.

(2) Designate a compliance officer who will be responsible for ensuring that:

(i) The anti-money laundering program is implemented effectively;

(ii) The anti-money laundering program is updated as necessary to reflect changes in the risk assessment, requirements of this chapter, and further guidance issued by the Department of the Treasury; and

(iii) Appropriate personnel are trained in accordance with paragraph (b)(3) of this section.

(3) Provide for on-going education and training of appropriate persons concerning their responsibilities under the program.

(4) Provide for independent testing to monitor and maintain an adequate program. The scope and frequency of the testing shall be commensurate with the risk assessment conducted by the dealer in accordance with paragraph (b)(1) of this section. Such testing may be conducted by an officer or employee of the dealer, so long as the tester is not the person designated in paragraph (b)(2) of this section or a person involved in the operation of the program.

  1. Fire Proof Silver, LLC will obtain and retain information of any person when/if it purchases the precious metals direct. Consistent with federal and local legal requirements will retain as a minimum full name, Date of birth, address, time & date of transaction, value of transaction and volume and type of precious metals exchanged and location of sale. Information will be taken direct from a legally recognized photo identification.
  1. One of the following forms of identification with a picture
    • S. driver’s license, or state or federally issue legal identification
    • Passport
    • Alien registration card

 

  1. If none of these forms of identification is available, the account can still be opened if the customer can supply two (2) of the following forms of ID.
    • Employer identification card
    • Major credit card

Two (2) current utility bills, showing the customer’s current address

Fire Proof Silver, LLC understands that the receipt of a National Security Letter (NSL) is highly confidential. We understand that none of our members or partners may directly or indirectly disclose to any person that the FBI or other federal government authority has sought or obtained access to any of our records. To maintain the confidentiality of any NSL we receive, we will process and maintain the NSL as only the 2 direct owners (Brandon LeMay and Annabelle LeMay) will have knowledge of or be involved with any such FBI correspondence. If we file a SAR after receiving an NSL, the SAR will not contain any reference to the receipt or existence of the NSL. The SAR will only contain detailed information about the facts and circumstances of the detected suspicious activity. 

                

Fire Proof Silver, LLC owners are aware that that “willful blindness” by a business of money laundering activities is a crime under 18 U.S.C. 1956 & 1957, punishable by fines of up to $500,000 and incarceration of up to five years. Furthermore Fire Proof Silver, LLC owners will always be proactive and dedicated to all legal and ethical financial matters in all regards. All laws and regulation are to be followed to include federal, state and city of Lacey. (Electronic file-signatures – Brandon LeMay & Annabelle LeMay)

Stumbauer, S (2017) FIVE STEPS FOR ANTI-MONEY- LAUNDERING COMPLIANCE IN 2017: https://internationalbanker.com/finance/five-steps-anti-money-laundering-compliance-2017/

Financial Crimes Enforcement Network – Resources online, https://www.fincen.gov/

Anti-money laundering article: http://www.finra.org/industry/aml

The FinCENT Suspicious Activity Report Introduction and filing Instructions RecordedPresentation.pdf:  https://www.fincen.gov/sites/default/files/shared/TheNewFinCENSAR-

Anti-Money Laundering (AML) Program: Compliance and Supervisory Procedures – Anti-money laundering Template (2018) http://www.finra.org/industry/anti-money-laundering-template-small-firms

Shuman, J.C. (1998) The Rhythm of Business: The key to building and running successful companies. Woburn, MA: Butterworth-Heinemann

31 CFR 1027.210 – Anti-money laundering programs for dealers in precious metals, precious stones, or jewels

RCW 19.60. Revised Code of Washington (2018) – state law “Pawnbrokers and secondhand dealers” 

RCW 19.60.020 Revised Code of Washington – state law “Duty to Record Information” 

Unlock Your Guide to AML U.S. Anti money Laundering Requirements 7th ed. (2018) https://www.protiviti.com/sites/default/files/united_states/insights/guide-to-us-aml-requirements-7thedition_protiviti.pdf

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