It is the intent and policy of NxSystems™ (the Company) to have a clear and concise understanding of all customer practices in order to avoid criminal exposure by any “customer” who would use the Company resources for illicit purposes. The objective of this policy is to ensure the immediate detection and identification of suspicious activity.
The Company recognizes that appearances can be deceiving. Potential customers may appear to be legitimate, but in reality could be conducting illicit activities. Likewise, legitimate customers may be turned away because their activities are perceived to have a criminal tone. It is also important to realize that various influences on legitimate customers may transform such customers into wrongdoers.
Accordingly, it is the policy of the Company to incorporate the following principles into its business practice:
- The Company shall make a reasonable effort to determine the true identity of all customers requesting the Company’s services;
- The Company shall obtain identification from all new customers;
- Personnel at the Company shall take reasonable steps to be aware of any unusual transaction activity or activity that is disproportionate to the customer’s known business.
An integral part of the Company “Know Your Customer” policy is a comprehensive knowledge of the transactions carried out by our customers. We shall collect sufficient information to develop a “transaction profile” of each customer. The primary objective of the procedure is to predict with relative certainty the types of transactions in which a customer is likely to be engaged. The Company procedures require proper identification of every customer at the time a relationship is established in order to prevent the creation of fictitious accounts. In addition, employee training and education program shall provide examples of customer behavior or activity that may warrant investigation.
As a general rule, the Company shall not establish a business relationship until the identity of the potential customer is satisfactorily established. If a potential customer refuses to produce any of the requested information, the relationship shall not be established. Likewise, if the potential customer is not forthcoming with requested follow-up information, any relationship already begun shall be terminated.
No Consumer account should be opened without conducting the following procedures, including, but not limited to:
- Obtaining satisfactory identification, such as:
- A drivers license issued by the State of Residence, State identification card, or alternatively, an out-of-state driver’s license; or
- A Government passport or alien registration card, photo identification card, or an employment identification card.
Business principals providing evidence of legal status (e.g., sole proprietorship, partnership or incorporation or association);
- No business account should be opened without conducting the following procedures that include, but are not limited to:
- Copy of principles ID, such as passport,
- Considering the source of the funds used to open the account. Large cash deposits should be questioned. Checks deposited shall be verified with the name of the account and/or maker and the appropriate holds placed as necessary; or
- For all commercial accounts, obtaining the following information:
- A financial statement on the business;
- A description of the customer’s principal line of business;
- A list of major suppliers and customers and their geographic locations;
- A description of the business’s primary trade area, and whether international transactions are expected to be routine; and
- A description of the business operations (i.e., retail versus wholesale, and the anticipated volume of cash sales).
Other Suspicious Transactions and Conduct
There are certain activities that are suspicious in nature and should alert us to the potential for the customer to conduct illegal activities. These activities include, but are not limited to:
- Insufficient, false, or suspicious information provided by the customer;
- Cash deposits that are not consistent with the business activities of the customer;
- Purchases and/or deposits of monetary instruments that are not consistent with the business activities of the customer;
- Wire transfer activity that is not consistent with the business activities of the customer;
- Structuring of transactions to evade record keeping and/or reporting requirements; or
- Funds transfers to foreign countries.
It is the intent and policy of the Company to have a clear and concise understanding of all customer practices in order to avoid criminal exposure by any “customer” who would use the Company’s resources for illicit purposes. The objective of this policy is to ensure the immediate detection and identification of suspicious activity.
The Compliance Officer for this policy is Debra Kennedy. The responsibility of the Compliance Officer is to ascertain that Company policy is in compliance with the current laws and regulations, and that the policy is communicated to the appropriate employees and agents.
All employees and agents have been provided with a copy of this policy. All new employees and agents will be provided with a copy of this policy at their time of hiring. It will be the responsibility of all managers to provide ongoing training regarding this policy and the procedures for compliance.
We appreciate your understanding and full cooperation in implementing this policy.
Senior Management approved this policy on January 1, 2008