Registered Office: Wyoming, United States
Operating Office: Miami Beach, Florida
Black Diamond Private Wealth LLC (“the Firm”) is committed to maintaining a robust Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance program designed to prevent the Firm from being used for money laundering, terrorist financing, fraud, or other financial crimes.
This policy establishes procedures to comply with applicable U.S. laws and regulations, including those administered by:
The Firm prohibits the use of its services for:
This AML program is implemented pursuant to:
This AML policy applies to:
It covers:
The Firm maintains a risk-based AML program consisting of the following components:
The Firm appoints an AML Compliance Officer (AMLCO) responsible for implementing and maintaining this program.
Responsibilities include:
The AMLCO reports directly to senior management.
The Firm adopts a risk-based AML framework consistent with guidance from the Financial Action Task Force.
Higher risk clients may include:
Riskier jurisdictions include those:
Higher risk services include:
In accordance with the USA PATRIOT Act, the Firm maintains a Customer Identification Program (CIP).
Before establishing a client relationship, the Firm must collect:
For individuals:
For entities:
Verification methods include:
The Firm conducts risk-based due diligence on all clients.
CDD includes:
For legal entity clients, the Firm identifies and verifies:
Documentation may include:
Enhanced Due Diligence is applied to higher-risk clients including:
EDD measures include:
The Firm screens clients against global PEP databases.
EDD is applied where a client is:
The Firm screens all clients and transactions against sanctions lists administered by the Office of Foreign Assets Control.
This includes:
Transactions involving sanctioned parties are prohibited.
The Firm maintains ongoing monitoring of client activity to detect suspicious patterns.
Red flags include:
Monitoring may be conducted via automated systems or manual review.
If suspicious activity is detected, the Firm will file a Suspicious Activity Report (SAR) with the Financial Crimes Enforcement Network.
Examples include:
SARs must be filed within 30 days of detecting suspicious activity.
Employees are prohibited from disclosing SAR filings.
If applicable, the Firm will comply with Currency Transaction Reporting (CTR) requirements for cash transactions exceeding $10,000 under the Bank Secrecy Act.
The Firm retains AML records for at least five (5) years, including:
Records must be securely stored.
The Firm conducts AML training for all employees.
Training covers:
Training is conducted annually.
The AML program is subject to independent review at least annually.
Testing may be conducted by:
Reviews assess:
All AML records and investigations are confidential.
Information will only be disclosed to regulators or law enforcement where required.
The Firm conducts due diligence on third parties including:
Third parties must maintain appropriate AML standards.
Employees must escalate suspicious activity to the AML Compliance Officer immediately.
Failure to report suspicious activity may result in disciplinary action.
The Firm will cooperate fully with:
This AML program will be reviewed annually and updated to reflect:
This policy is approved and adopted by the management of Black Diamond Private Wealth LLC and is effective immediately.
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