A. Saxon Donegan New York, LLC (“Saxon Donegan”) is fully committed to complying with all of the requirements of the Patriot Act, and all other applicable rules and regulations relating to anti-money laundering (AML) as promulgated by the Commodity Futures Trading Commission and the National Futures Association. It is Saxon Donegan’s policy to avoid any instance where it may be used to aid or abet a money-laundering scheme.

B. Currently, Saxon Donegan requires valid photo identifications from its customers. If the photo identification does not completely match the information provided on the customer account documentation, then further non-documentary methods will be used to verify the identity of the customer. In addition, Saxon Donegan will review the latest Financial Action Task Force (“FATF”) List to ensure no accounts originate from areas that have been deemed to be non-cooperative. For U.S. and Foreign corporate accounts, Saxon Donegan will obtain appropriate corporate documents.

C. Saxon Donegan will require AML training on at least an annual basis to appropriate personnel. All training certificates will be maintained for five years. Failure to adhere to AML Policy may subject Saxon Donegan’s employees, registered persons and affiliates to disciplinary action, up to and including termination of employment and/or registration.

D. Saxon Donegan informs the customer that information is being obtained to verify the customers’ identity and that background checks are going to be performed. Saxon Donegan performs due diligence to ensure that the appropriate notice is included in the customer account documentation process. Saxon Donegan will provide the following notice to it prospective customers:

If you are contemplating opening futures related trading accounts with Saxon Donegan New York, LLC, you should be aware of the following:
To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for you is that when you open an account, we will ask for your name, address, date of birth, social security number, and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents and perform background checks on you.