William O’Neil + Company AML Policy

William O’Neil + Company, as an Independent Advisory firm, has a responsibility and a commitment to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. To fulfill this goal we have implemented a specific, comprehensive, internal Anti-Money Laundering Policy. Associates of William O’Neil + Company are considered members of the William O’Neil + Company team, and individually share in the responsibility of fulfilling this commitment. To that end, all William O’Neil + Company associates are apprised of this policy so even those who don’t trade understand our obligations.

What is Money Laundering?

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages: 1. cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s checks, or deposited into accounts at financial institutions; 2. at the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin; and 3. at the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses. Terrorist financing may not involve the proceeds of criminal conduct, but rather attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.

The Regulations

On October 26, 2001, President George W. Bush signed into law the USA PATRIOT Act, which, among other things, strengthens the anti-money laundering provisions put into place by earlier legislation.