January 02, 2020,
Green Energy Solutions has voluntarily established and continues to maintain a Global Anti-Money Laundering Policy, designed to ensure, that at a minimum, Green Energy Solutions is in compliance with all applicable laws, rules and regulations related to anti-money laundering and anti-terrorist financing initiatives. Among other relevant laws, the Global Anti-Money Laundering Policy adheres to pertinent provisions of the USA PATRIOT Act, which prohibits transactions and client relationships with individuals and entities on the U.S. Department Of Treasury’s OFEC list; requires financial institutions to establish due diligence policies, procedures, and controls reasonably designed to detect and report money laundering through appropriate channels; and, mandates financial institutions to conduct enhanced scrutiny of certain entities maintained by or on behalf of senior foreign political figures. As an unregulated, non-bank financial institution, Green Energy Solutions is not required to comply with these provisions but has chosen to comply voluntarily.
- Procedures to implement the Green Energy Solutions Customer Identification Program and a system of internal controls to ensure that appropriate due diligence, and when necessary, enhanced due diligence, including obtaining and maintaining appropriate documentation, is conducted at the inception of client relationships and updated, as necessary, through the course of the customer relationship;
- The designation of an Anti-Money Laundering Compliance Officer, or other appropriate personnel, responsible for coordinating and monitoring day-to-day compliance with the Global Anti-Money Laundering Policy and applicable laws, rules and regulations;
- Recordkeeping and reporting practices in accordance with the Global Anti-Money Laundering Policy and applicable laws, rules and regulations, including the Bank Secrecy Act;
- Appropriate methods of monitoring transactions and client relationships to identify potential suspicious activity;
- Reporting of suspicious activity to governmental authorities in accordance with the Global Anti- Money Laundering Policy and applicable laws, rules and regulations;
- Training of appropriate personnel with regard to anti-money laundering and anti-terrorist financing issues and their responsibilities for compliance; and
- Independent testing to ensure that the programs required by the Global Anti-Money Laundering Policy and applicable laws, rules and regulations have been implemented and continue to be appropriately maintained.
Green Energy Solutions has undertaken appropriate due diligence to know its customers. There is no reason to believe that any of Green Energy Solutions customers are prohibited shell banks, an individual or entity that is named on a list issued by the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC"), or an individual or entity that resides, is organized or chartered, or has a place of business, in a county or territory subject to OFAC's various sanctions/embargo programs, except for customers with whom OFAC has expressly provided authority for transactions by means of regulations, rulings, instructions, licenses or otherwise, or named on any available government lists of known or suspected terrorists or terrorist organizations issued by the government of the jurisdiction in which Green Energy Solutions conducts business, as applicable.
As a global, non-bank financial institution that offers Renewable Energy Advisory and Brokerage services to customers around the world, Green Energy Solutions recognizes its obligation to join with governments, international organizations and other members of the financial industry to help close off the financial channels that terrorists and money launderings use for their illicit purposes.
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