**H&W Investments Limited**

Anti-Money Laundering (AML) Program: Compliance and Supervisory Procedures

**UPDATED AS OF MAY, 2024**

Firm Policy

H&W Investments Limited adheres strictly to the Anti-Money Laundering regulations mandated by the Bank Secrecy Act (BSA) and enforced through FINRA Rule 3310. Our firm is dedicated to preventing money laundering and the financing of terrorist activities through vigilant and robust compliance practices. Money laundering is defined as the process where the identity of the proceeds of crime is so disguised that it appears to have originated from a legitimate source.

The key stages of money laundering include:

  1. Placement: Introducing illicit funds into the financial system.
  2. Layering: Concealing the source of the funds through a series of transactions and bookkeeping tricks.
  3. Integration: The funds re-enter the economic mainstream as legitimate funds.

While securities transactions are not typically cash-based, our industry can inadvertently be used to launder money through complex trading instruments or by moving funds within and across borders. This includes potential fraudulent activities like insider trading, market manipulation, and ponzi schemes.

AML Compliance Officer Designation and Duties

H&W Investments Limited has designated [Compliance Officer’s Name] as the Anti-Money Laundering Program Compliance Officer (AML Compliance Officer). This officer is equipped with a comprehensive understanding of the BSA and associated regulations. The responsibilities include:

  • Monitoring the firm’s adherence to AML regulatory standards.
  • Conducting regular training sessions for all employees on AML procedures.
  • Ensuring proper reporting of suspicious activities to the relevant authorities.

Our firm commits to maintaining all records as required by the BSA and regularly updating our AML strategies to reflect any changes in legislation and operational scope.

Customer Identification Program (CIP)

At H&W Investments Limited, every new client must undergo a stringent verification process as part of our Customer Identification Program. We collect essential information such as name, date of birth, address, and an identification number. This data is verified using reliable and independent sources to ensure authenticity. Our program is designed to be comprehensive and is regularly reviewed to ensure it addresses the evolving risks associated with money laundering and terrorism financing.

For existing clients, periodic reviews are conducted to ensure that our records are up-to-date and reflect the true nature of the ongoing business relationship. This is crucial for accounts that exhibit a high risk of money laundering or are involved in complex transactions.

Enhanced Due Diligence

For clients and transactions presenting higher risks, such as those from countries with deficient AML standards or clients involved in high-risk industries, H&W Investments Limited employs enhanced due diligence procedures. These measures include deeper scrutiny of the sources of funds, the nature of transactions, and the purpose of the business relationship.

Training and Compliance

All employees at H&W Investments Limited receive regular training on AML regulations and the firm’s internal policies and procedures. This training ensures that all staff are aware of their roles in preventing money laundering and know how to identify and report suspicious activities.

Conclusion

H&W Investments Limited is fully committed to upholding the highest standards of financial integrity and transparency. By implementing a robust AML program, we not only comply with regulatory requirements but also safeguard our reputation and the interests of our clients.