Anti-Money Laundering Program

August 2017

Policy Statement

It is the policy and practice of BBBSecurities to prevent and prohibit identified criminal activity. The AML Program is designed, based on size, location, business activities, types of customers and types of transactions, to ensure that BBBSecurities it is not used, or taken advantage of by criminals.

Background

Our AML starts at our front door, which is protected with a dumaflatchy lock.   It is a strong deadbolt.  Once inside, and we will not tell you about the layout for obvious reasons, but we have a 9 shot 12 Gauge DS Police Special Ithaca Model 37 pump shotgun strategically placed.  We don’t know exactly what it is loaded with.  We do know they are hand loads.  We were hunting pheasants  in the Panhandle and observed this guy knocking birds down out to 60 yards.  So, we saddled up to him and quizzed him about what was he shooting.  It turns out, he was shooting extra powerful hand loads.  We obtained 10 rounds from him and that is what is in the gun!

Then in March of 2009 with a customer of a financial advisor in North Dallas associated with another Broker/Dealer, Williams Financial Group, opening fire on a Father/Son selling team, and shooting one of them four times, we moseyed over to Cabela’s in Fort Worth and acquired a 12 round Taurus PT 24/7 PRO Cal .45 ACP pistol with a Soft Armor holster to keep this pistol in another strategic location. It is loaded with 12 rounds of Federal Premium HYDRA-SHOK bullets. These bullets go in like you would punch the end of an Office Depot Jumbo paper clip into a biscuit or roll, but they come out the other side like an opened umbrella.

We can assure you that we do not do any robo-signing like the banks do.  Our signature may look like a robot signed it, but that is just me.  Neither do we use deceased notaries to notarize anything.  Our notary is Judy Anderson with my landlord’s insurance agency and she is a very respectable lady and just full of life!  If you are crooked we don’t want your business!  WE CAN’T BE ANY MORE BLUNT THAN THAT!

Being a one man shop, we can’t afford a full time police officer guard like some banks have in the lobby, but we have taken a page from Homeland Security and as far as we know, we are the only Broker/Dealer with an Anti $Laundering “Sniffer Dog!”  Ms Serena is a rescued Greyhound from the tracks in Colorado from Greyhounds Unlimited, please go to their website and get you one too!  http://www.greyhoundsunlimited.org/ Ms Serena is faster than a wire transfer, more powerful than a margin call, able to leap a Washington Mutual banking lobby kiosk at a single bound. WAMU is currently known as JPMorgan Chase, but based on foreclosure gate and their supposed silver short, that name may very well change again in the future too.

This is fairly easy to follow, but the rest is more complicated.

The PATRIOT Act is designed to detect, deter, and punish terrorists in the United States and abroad and to enhance law enforcement investigation tools by prescribing, among other things, new surveillance procedures, new immigration laws, as well as new and more stringent AML laws. The Money Laundering Abatement Act expands and strengthens the AML provisions put into place by earlier legislation (e.g. Bank Secrecy Act).

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origin of criminally derived proceeds so that the unlawful proceeds appear to have derived from legitimate origins or constitute’legitimate assets. Money laundering occurs in connection with a wide variety of crimes, including, but not limited to, drug trafficking, robbery, fraud, racketeering, and terrorism. In general, money laundering occurs in three stages:

  • Placement – Cash first enters the financial system at the “placement” stage, where the cash profits from criminal activity are converted into monetary instruments, such as money orders ortraveler’s checks, or deposited into accounts at financial institutions.
  • Layering – At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to separate further the proceeds from their criminal origin.
  • Integration – At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund further criminal or legitimate activities.

Non-compliance with BSA requirements can have severe consequences, including civil and possible criminal penalties.