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Corporate and Regulatory Compliance Policies

Anti-Money Laundering - OFAC

This policy detects suspicious financial transactions such as tax evasion or false accounting, especially with entities that appear on the U.S. OFAC list.

Bid Rigging Detection: Insurance

This policy identifies ‘B’ bids, and other electronic communications indicative of bid rigging, as it relates to the insurance industry.

Bid Rigging Detection: Municipal Bond Issuance

This policy detects language that indicates possible bid rigging related to Municipal Bond issuance.

Blast E-Mail

This policy monitors for blast e-mail which is sent to more than a specified number of external recipients at one time.

Bribes/Kickbacks/Quid Pro Quos/Blackmail

This policy detects involvement in bribery or blackmail schemes.

Broker Error

This policy detects indications that a broker has made or is attempting to correct an error with respect to trading.

Communication with Regulatory, Legal, and Governmental Authorities

Protect and control communications between an employee and regulatory, legal, and governmental authorities.

Fair and Balanced Advice

This policy detects unbalanced communication by recognizing claims and statements that focus solely on positive or negative aspects of a product, advice, or decision.

Information Destruction Alert

Electronic information can be eliminated as easily as it is created, making the uncontrolled destruction of retained information an unacceptable risk. This policy detects text indicative of a suggestion to eliminate e-mail messages, computer files, or documents. It also detects general references to retention rules.

Investment Advice Prohibition

This policy detects messages that appear to contain investment advice or recommendations.

Securities Parking

This policy is designed to look for evidence of two parties engaged in a possible "trade parking", or "wash trade", arrangement.

Solicitations: Charitable

This policy detects solicitations or requests for contributions to charities, student fundraisers, or other non-commercial and non-political organizations.

Solicitations: General

This policy detects language containing general references to contributions or solicitations for contributions.

Solicitations: Political

This policy detects solicitations or requests for contributions to political causes or campaigns.

Solicitations: Private Investments

This policy detects language containing references to contributions or solicitations for contributions to private investment activities.

Solicitations: Religious

This policy detects solicitations or requests for contributions to religious organizations.

Tax Advice Prohibition

In general, a Representative must be both qualified, and allowed by the firm, in order to offer ‘advice’ to a customer. This policy is designed to identify messages where a non-tax Professional offers tax advice to a public customer.

Trading in an Outside Account: Order Confirmations

This policy detects order confirmations so as to identify trading activity, for one’s personal account, outside of firm-approved processes and/or procedures.

Trading in an Outside Account: Order Placements

This policy is designed to identify trade order placements, for one’s personal account, outside of Firm-approved processes and/or procedures.

Whistleblower

This policy detects possible whistle blower situations and allows an organization to take appropriate steps in response.