Anti-Money Laundering Policy
“Money laundering” refers to those acts utilized by criminals to derive proceeds from crimes to “clean” money by disguising and/or concealing the actual source and/or destination of proceeds; further “terrorist financing” refers to those acts, such as terrorist groups, etc., utilized to provide funds for terrorism activities (hereinafter collectively referred to as “money laundering, etc.”). Due to increasingly sophisticated criminal schemes and skills, OHC has taken into consideration the importance of the measures against financing of terrorism based on the international community’ s determination to combat terrorism and terrorist activities. OHC has developed this written policy for anti-money laundering in order to prevent funds or assets from being channeled for criminal or terrorist activities.
As a precious metals dealer duly licensed with the Ohio Department of Commerce, Division of Financial Institutions, OHC recognizes the importance of countermeasures against money laundering, etc. In order to respond to calls made by the national and international communities to fight money laundering and terrorist efforts, we will conduct our business in compliance with our internal control system(s). For more questions regarding our policy please write Old Hilliard Coin & Fine Art, LLC at 5275 Norwich Street, Hilliard, OH 43026.
Management
We clearly stipulate roles within us for anti-money laundering, etc., pursuant to our internal Anti-Money Laundering Policies and Procedures Plan.
Customer Identification
We employ and maintain appropriate measures to conduct customer identification. Specifically, management will train employees in matters related to the prevention of money laundering so that employees can implement immediate and appropriate measures for customer identification.
Reporting of Suspicious Transactions, etc.
We employ and maintain measures for handling suspicious transactions.
We report suspicious transactions to relevant authorities without delay.
We take appropriate actions against suspicious transactions without delay.
We train employees in matters related to the prevention of money laundering, etc., so that employees can take appropriate actions in a timely manner for handling suspicious transactions.
Check and Monitoring
We check and monitor whether we are compliant with regulations through the use of a designated compliance officer for anti-money laundering, etc., and continuously improve our system based on the results.