Natus Trade LTD. and its associates are committed to ensuring full compliance with all applicable federal and state laws, regulations, and industry standards regarding anti-money laundering (AML). The Executive Director of Natus Trade LTD. holds program responsibility for AML, ensuring policies are current, and that all necessary filings are accurate and timely.

The Executive Director is also responsible for implementing and maintaining AML practices and procedures, acting as the primary contact for AML compliance. Questions may be directed to the Executive Director

Who Is Covered by The AML Program?

The Anti-Money Laundering Program of Natus Trade LTD. applies to all Company operations and includes:

• Development of internal policies, procedures, and controls;
• Designation of a compliance officer;
• Ongoing employee training;
• An independent audit function to test programs.

What Is Money Laundering?

Money laundering is the process by which criminals conceal the existence, source, or nature of illegally derived funds. It typically involves three stages:

• Placement: Initial placement of illegal funds into the financial system.
• Layering: Creating transactions to obscure the origin of funds.
• Integration: Reintegrating the "clean" funds into society.

Anti-Money Laundering Regulations

The U.S. Government enforces AML laws through the Treasury Department, including the following:

• Bank Secrecy Act (BSA): Requires currency transaction reports, wire transfer documentation, and more.
• Internal Revenue Code (IRC 60501): Requires reporting of currency transactions over $10,000.
• U.S.A. Patriot Act: Mandates financial institutions to develop and implement AML programs.
• OFAC: Enforces trade restrictions against certain individuals, organizations, and countries.

Consequences For Failure To Comply

Non-compliance may result in severe penalties, including imprisonment, fines, and forfeiture of property. Employees may face disciplinary actions up to termination.

AML Compliance Procedures and Responsibilities

Details on the Anti-Money Laundering Program procedures are available in the “Natus Trade LTD. Anti-Money Laundering Corporate Procedures Guide.”

Ongoing Agent and Employee Training Program

The Company has a training program to educate employees and agents on AML, including identifying red flags, understanding their roles, and complying with record retention policies. Training occurs at least annually.

Anti-Money Laundering Guidelines

Agents’ and Employees’ Obligations For AML Compliance

Natus Trade LTD. personnel must avoid transactions linked to criminal activities. Specific AML procedures are outlined in the Corporate Procedures Guide.

Suspicious Activity Monitoring and Reporting

The Company will file Suspicious Activity Reports (SARs) with FinCEN for transactions over $5,000 with suspicious elements.

Cash Reporting

The Company files IRS Form 8300 for reportable cash events and prohibits cash payments for securities transactions.

Wire Transfers

The Company does not process wire transfers.

Recognizing and Preventing Structured Transactions

Structured transactions designed to evade reporting requirements are prohibited. Examples include breaking transactions into amounts under $10,000.

Know Your Customer (KYC) Rules

The Company verifies client information and checks against OFAC's list of terrorists and sanctioned entities before opening accounts.

Prohibition on U.S. Correspondent Accounts With Foreign Shell Banks

The Company prohibits establishing or maintaining U.S. accounts with foreign shell banks.