HSO Global LLC, Huron Smith Oil CO INC, and HSO Petroleum Services LLC (“HSO Global”, “we”, “us”, “our”) are fully committed to preventing money laundering and terrorist financing. This AML Policy establishes the principles, procedures, and controls we have implemented to detect, prevent, and report suspicious activity, in compliance with the Bank Secrecy Act (BSA), the USA PATRIOT Act, FinCEN regulations, and supplementary Florida and Mississippi criminal provisions.
1. PURPOSE
Prevent our services from being used for money laundering or terrorist financing while ensuring full regulatory compliance.
2. SCOPE
Applies to all personnel, collaborators, and business relationships involving financial transactions.
3. DEFINITIONS
- Money Laundering: The process of concealing the origins of illegally obtained money.
- Terrorist Financing: The provision of funds or resources to support terrorist activities.
- Red Flag: An indicator or warning sign of potential money laundering or terrorist financing activity.
4. AML COMPLIANCE OFFICER
Designation: Appointed with sufficient authority.
Responsibilities: Policy development, training, monitoring, SAR filing, audits, record-keeping.
5. CUSTOMER DUE DILIGENCE (CDD)
- Identification and Verification: Collect and verify identity and beneficial ownership.
- Risk Assessment: Low/medium/high risk; Enhanced Due Diligence (EDD) for high risk.
- Ongoing Monitoring: Continuous transaction monitoring and periodic updates.
6. REPORTING SUSPICIOUS ACTIVITY
- Internal Reporting: Immediate report to AML Officer.
- External Reporting: SAR to FinCEN/state agencies if warranted.
- No Tipping Off: Strict prohibition on informing the subject.
7. RECORD KEEPING
Minimum five (5) years after relationship ends.
8. TRAINING AND AWARENESS
Initial and annual training; ongoing awareness.
9. SANCTIONS AND WATCHLISTS
Screening against OFAC, UN, EU lists; no dealings with sanctioned parties.
10. CONSEQUENCES OF NON-COMPLIANCE
Discipline, termination, legal notification.
11. POLICY REVIEW AND UPDATES
Annual review or immediate upon regulatory changes.
12. CONTACT
For any questions, communications, or reports related to this AML Policy, please contact the AML Compliance Officer through the following channels:
- Email: legal@huronsmithoil.com
- Phone: +1 (866) 954-5938
- Postal address (Florida): HSO Global LLC, 66 West Flagler Street, Suite #900, Miami, FL 33130, USA.
- Postal address (Mississippi): Huron Smith Oil Co Inc / HSO Petroleum Services LLC, 204 Hays St, Batesville, Mississippi 38606, USA.