It is the policy of TechForm Advanced Casting Technology (“TechForm”) to prohibit the use of our business or services for money laundering or terrorist financing.
This AML Program and Policy has been developed in conformance with the requirements of rules promulgated by the U.S. Department of Treasury, Financial Crimes Enforcement Network, 31 CFR Chapter X, Part 1027, under the Bank Secrecy Act as amended by the USA PATRIOT Act of 2001 (Pub.L.107-56) and is based on TechForm’s assessment of the money laundering and terrorist financing risks associated with TechForm’s transactions pertaining to covered goods.
This Program and Policy will be made available to the U.S. Department of Treasury or any other duly authorized government agency upon request.
Both this AML Program and Policy and TechForm’s Risk Assessment have been reviewed and approved by Senior Management, including the President of TechForm. Both this Program and the Risk Assessment may be updated from time to time and is available for review at any time.
This Program and Policy applies only to the purchase and sale of covered goods defined as precious metals (of an assay in excess of 500 parts per thousand), precious stones and jewels, and finished goods of which 50% of the value is derived from the precious metals, precious stones or jewels contained in or attached to such goods. Currently, TechForm only deals in precious metals.
- It is the policy of TechForm to comply with all cash reporting requirements for receipt of cash in a single transaction or in a series of related transactions in an amount of $10,000 or higher. In all such cases, an IRS Form 8300 will be completed in full and submitted to the appropriate government agency.
- It is the policy of TechForm to only work with business partners, suppliers, and customers operating the U.S. or Canada. If in the future TechForm needed to open a foreign bank or other foreign financial institution account, the relevant IRS forms would be filed and, when appropriate, the appropriate IRS form pertaining to the international transportation of currency or monetary instruments as required by law.
- Currently it is the policy of TechForm to not purchase precious metals from members of the public, but if in future it was necessary, TechForm will complete and submit to the appropriate government agencies documents required under state law associated with the purchase of finished goods or other precious metals from members of the public.
- Any request from a business partner of TechForm to alter its course of dealing with TechForm will be the subject of reasonable inquiries designed to determine the reasons for the change in course of dealing. Changes in course of dealing can include but are not limited to: change in payment (receivable or payable) methods or locations, change in delivery methods or locations, introduction of heretofore unknown third parties into the course of dealing, change in the chain of distribution.
- Any request from a business partner of TechForm for an unusual degree of secrecy related to the transaction will be the subject of reasonable inquiries designed to determine the reasons for the high degree of secrecy.
- It is the policy of TechForm that, when the person or company supplying or purchasing covered goods, evades or refuses to respond to reasonable inquiries by TechForm to acquire information or explanations required for compliance with the TechForm AML program to refer the transaction to the Compliance Officer for assessment.
- It is the policy of TechForm to train all relevant employees regarding the laws and regulations pertaining to anti-money laundering requirements and the program and policy of TechForm and to always have the program and policy available. A hard copy will be kept in the administration office and a digital copy on the server.