AML Policy

In consideration of CODA Markets, Inc. (“CODA MARKETS”) facilitating orders on behalf of its Subscribers and/or their clients, by using the CODA MARKETS System, each Subscriber approved to use the CODA MARKETS System agrees and confirms that:

(i) It is a financial institution regulated by a Federal functional regulator (which includes, among others, a broker-dealer registered with the Securities and Exchange Commission).

(ii) It has established and has in effect, and agrees to maintain, written anti-money laundering (“AML”) policies and procedures that comply with the USA Patriot Act of 2001 and the Bank Secrecy Act (31 U.S.C. 5311, et seq.) (together, the “AML Laws”), to the extent applicable.

(iii) Its AML policies and procedures meet or exceed the requirements of the AML Laws.

(iv) It will designate, and identify to CODA MARKETS (by name, title, mailing address, e-mail address, telephone number, and facsimile number), a person or persons responsible for implementing and monitoring the day-to-day operations and internal controls of the AML program and provide prompt notification to CODA MARKETS regarding any change in such designation(s).

(v) With respect to each client that Subscriber introduces to CODA MARKETS: Subscriber is acting as an intermediary or nominee for the subscriber/client.

Pursuant to Subscriber’s AML policies and procedures, Subscriber has in place policies and procedures that verify the identity of the subscriber/client, and if not an individual, its beneficial owners; that can be reasonably expected to detect and cause the reporting of transactions (monetary, securities trading or otherwise) required under 31 U.S.C. 5318(g) and the implementing regulations thereunder, as applicable, and that are reasonably designed to achieve compliance with the Bank Secrecy Act and the implementing regulations thereunder, as applicable.
 Pursuant to Subscriber’s policies and procedures, Subscriber has taken or will take reasonable steps to verify that Subscriber has not received money or securities from any illicit activity from the subscriber/client.