The purpose of this policy is to:
• Detect and report suspicious activities that may be related to money laundering, terrorist financing, or other financial crimes.
• Comply with federal AML regulations to prevent the use of Alphawave Metal Trading LLC for illicit purposes.
• Promote ethical business conduct in precious metal trading, particularly gold
This policy applies to all employees, contractors, officers, and agents of Alphawave Metal Trading LLC involved in the trading of gold and other precious metals. It covers all aspects of the business, including:
• Purchasing and selling gold.
• Customer onboarding and due diligence.
• Reporting and record-keeping
The following laws and regulations apply to this AML policy:
• Bank Secrecy Act (BSA): Requires financial institutions to keep records and file reports that may be useful in detecting and preventing money laundering.
• USA PATRIOT Act: Strengthens the BSA by requiring enhanced customer due diligence and implementing stricter AML compliance standards.
• FinCEN Regulations: Mandates precious metal dealers to establish AML programs and file suspicious activity reports (SARs) as necessary
• Money Laundering: The process by which criminals disguise the original ownership and control of the proceeds of criminal conduct by making such proceeds appear to come from a legitimate source.
• Terrorist Financing: The use of funds, directly or indirectly, to support terrorist activities or organizations.
• Precious Metals Dealer: Any person or entity that buys and sells precious metals, including gold, and meets the thresholds established by FinCEN
Alphawave Metal Trading LLC will implement a Customer Identification Program to verify the identity of every customer involved in gold transactions. The CIP will include the following steps:
• Customer Due Diligence (CDD): Collection of customer identification information, including name, address, and date of birth (for individuals), or company registration information (for entities).
• Enhanced Due Diligence (EDD): For higher-risk customers, including politically exposed persons (PEPs), and transactions exceeding $10,000, additional verification steps will be taken.
Documents Required for Identification:
• For Individuals: Government-issued ID, such as a passport or driver’s license.
• For Businesses: Corporate documents, including incorporation certificates, tax identification numbers, and information on beneficial owners
Employees must be vigilant in identifying suspicious transactions, such as:
• Large, unexplained cash transactions.
• Transactions that have no apparent economic or lawful purpose.
• Customers providing incomplete or false identification information.
Alphawave Metal Trading LLCwill:
• File a Suspicious Activity Report (SAR) with FinCEN within 30 days if suspicious activities are identified.
• File a Currency Transaction Report (CTR) for any transactions exceeding $10,000 in cash.
Alphawave Metal Trading LLC will maintain the following records for a minimum of five years:
• Customer identification records.
• Transaction records for gold purchases and sales.
• Suspicious activity reports (SARs) and other regulatory filings.
• Any additional documents relevant to the company’s AML compliance
To ensure ongoing compliance, Alphawave Metal Trading LLC will:
• Regularly review and update the AML policy as necessary.
• Appoint a qualified AML Compliance Officer to oversee the implementation of this policy.
• Conduct regular internal audits and risk assessments to identify areas of improvement in the company’s AML program.
Alphawave Metal Trading LLC will provide ongoing AML training to all employees involved in gold trading. This training will cover:
• AML regulations and compliance obligations.
• How to detect and report suspicious activity.
• The importance of due diligence and record-keeping.
Training sessions will be conducted annually, with additional training provided as needed based on changes in regulations or company operations.
The designated AML Compliance Officer for Alphawave Metal Trading LLC is responsible for:
• Overseeing the day-to-day implementation of this AML policy.
• Ensuring the company’s compliance with applicable AML regulations.
• Reporting suspicious activities to FinCEN and other regulatory bodies.
Name of Compliance Officer: Mirza Arshad Ali Baig
Contact Information: +1 630 518 2463
Failure to comply with this AML policy may result in severe consequences for both the company
and its employees. Potential penalties include:
• Civil and criminal penalties imposed by federal regulators.
• Termination of employment for employees found to be non-compliant.
• Reputational damage to the company and potential loss of business licenses.
This AML policy will be reviewed annually and updated as necessary to reflect changes in
regulations, industry practices, and company operations.
Last Reviewed: 04/20/2024 Next Review Date: 04/20/2025
MIRZA ARHSAD ALI BAIG
OWNER, COMPLAINCE OFFICER
04/20/2024
1. Red Flags for Suspicious Activity:
• Unusual trading patterns in gold transactions.
• Customers trying to evade reporting requirements by structuring transactions just below the $10,000 threshold.
• Inconsistent customer information across multiple transactions.
2. High-Risk Customers:
• Politically exposed persons (PEPs).
• Non-resident customers without a clear business relationship in the U.S.
• Clients from jurisdictions with weak AML controls.
