Anti Money Laundering Policy (AML)

It is the policy of i-Cthru Inc. (“i-Cthru”) not to provide services to persons or entities that have connections to organized crime, violent crime, drug trafficking, arms trafficking, foreign official corruption or terrorism. We will not accept any client that carries a high risk of involvement with any of the above activities without first conducting the due diligence requires establishing that the prospective client is not precluded by this policy.

Verification of Client Identity

i-Cthru requires documentary evidence of each individual client’s name, current address and phone number and date of birth. Additional documentary verification of current address and other contact information may also be required.

Suspicious Activity Reporting

The Chief Compliance Officer will file a suspicious activity report (FinCen Form 101: SAR-SF) if

The name of each prospective client screened through the U. S. Office of Foreign Asset Control (“OFAC”) appears on the List of Specially Designated Nationals and Blocked Persons. The List is made available through the U.S. Department of the Treasury on its web sitehttp://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/default.
i-Cthru, in connection with its advisory services, identifies any activity on the part of a Firm client with persons or entities that appear on any government list of restricted persons, and upon further investigation into the matter, it is determined that suspicious activity may have occurred.
i-Cthru detects, or reasonably suspects, a federal criminal violation or attempted violation by one of the Firm’s clients, officers or employees or any other suspect using i-Cthru’s services or facilities.
i-Cthru detects or suspects that its computer systems have been accessed by persons or entities to remove, steal, procure or otherwise affect the Firm’s client or own accounts or other critical information or to damage or disable the Firm’s computer systems and databases.
SARs must be filed within 30 days of the detection of the suspicious activity. Records of reports filed must be kept for a minimum of five years.

i-Cthru maintains a hard copy file of each suspicious activity report for five years from the date the report is filed.

Currency Transaction Reporting (CTR)

Since i-Cthru does not have custody of clients’ assets, it is unlikely that i-Cthru will be called upon to report client currency transactions. Nevertheless, if a currency transaction of $10,000 or more, is mistakenly accepted, the Chief Compliance Officer must immediately be notified and will return the currency to its source. If warranted, the Chief Compliance Officer may determine to file a Currency Transaction Report (CTR). Records of reports filed must be kept for a minimum of five years.

CTRs must be filed within 15 days of the transaction.

Currency or Monetary Instrument Transport Reporting (CMIR)

i-Cthru prohibits the receipt of currency. If an employee discovers that currency of $10,000 or more nevertheless has been received from a source outside the U.S., the Chief Compliance Officer must be notified immediately and will file a CMIR with the Commissioner of Customs.

In any case where i-Cthru transports, mails, ships or receives or causes or attempts to transport, mail, ship or receive monetary instruments of more than $10,000 in or out of the U.S., at one time (on one calendar day or, if for the purposed of evading the reporting requirements, on one or more days), the Chief Compliance Officer must be notified immediately and will file a CMIR, as required.

Records of reports filed must be kept for a minimum of five years.