Anti-Money Laundering (AML) Policy

Policy Statement

Harrington Capital is committed to preventing money laundering and terrorist financing. We maintain comprehensive AML compliance programs in accordance with the Bank Secrecy Act (BSA) and applicable federal regulations.

Customer Due Diligence (CDD)

Our CDD procedures include:

• Verification of customer identity using government-issued identification
• Verification of business entity registration and legitimacy
• Assessment of the nature and purpose of customer relationships
• Ongoing monitoring of customer transactions and activities
• Enhanced due diligence for high-risk customers

Suspicious Activity Reporting

We monitor all transactions for suspicious activity and file Suspicious Activity Reports (SARs) with FinCEN when required. Our team is trained to identify red flags indicating potential money laundering.

Record Keeping

We maintain comprehensive records of customer identification, transaction history, and due diligence documentation for the periods required by law (typically 5 years).

Training and Awareness

All Harrington Capital personnel receive regular AML training to ensure awareness of regulatory requirements, internal policies, and red flag indicators.

Independent Testing

Our AML program is subject to independent testing and audit to ensure effectiveness and regulatory compliance.

Contact

For questions about our AML policy:
Email: support@harringtoncapital.net
Phone: (929) 792-6599