Anti-Money Laundering Policy

Money laundering is the processing of criminal proceeds to disguise their illegal origin.

IKON Atlantic has a comprehensive Anti-Money laundering policy, an outline of which is set out below.

Senior management of IKON Atlantic have a responsibility to ensure that the firm’s control processes and procedures are appropriate and effectively implemented to counter the risk of the firm being used to money laundering and financial crime. Senior management are fully involved in the processes and take ownership of the risk-based approach.

The firm’s Money Laundering Reporting Officer (MLRO) will provide an annual report to the directors on the operation and effectiveness of the firm’s systems and controls to combat money laundering and financial crime. When the report is received senior management will consider the findings and take any action that is required.

Money Transfer Policy Overview:

IKON Atlantic will not, under any circumstances, accept funds from a remitter where the ordering party is not also the beneficiary i.e. No Third Party transfers are accepted, and funds are either returned as unapplied or a dependent on determination of the firm’s Compliance Officer.

Likewise IKON Atlantic will never disburse funds to a Third Party, and will always “return to sender” i.e. Client Account at IKON to Client account at correspondent bank where the original transfer was made.

Customer Due Diligence

Our firm’s obligations for conducting CDD as well as describing those situations and customers where either “Simplified Due Diligence” (“SDD”) can be applied or where “Enhanced Due Diligence” (“EDD”) must be used.

Core obligations on the firm are:

The prescribed CDD measures must be carried out for all customers not covered by exemptions;
Systems must be in place for dealing with those who are unable to produce ‘standard evidence’
EDD must be applied in higher risk cases where the customer is not present and also in relation to Politically Exposed Persons (PEPs);
Awareness that some persons/entities must not be dealt with and systems are in place for keeping information up to date.
CDD measures that must be carried out involve :Identifying the investor and verifying their identity; Identifying the beneficial owner where relevant and verifying their identity; and obtaining information on the purpose and intended nature of the business relationship
The firm monitors and adapts this process as required.
For further enquiries, please contact us at info@ikonatlantic.com

For further details on AML and KYC Policies please click here.

The use of Hyperlinks

IKON’s web site may contain hyperlinks or “links” to third party sites, and other sites may also “link” to our sites. Any web sites linking to and from our sites may have privacy practices different from IKON’s. Our web site Privacy Statement applies solely to information collected by our web sites. IKON is not responsible for the privacy policies or the content of sites you link to, and we have no control over the use or protection of information provided by you or collected by those sites. You should also be aware that where such site is located outside the EEA, there may be no equivalent legislation or privacy policy governing the use of personal data. If you choose to link to a co-branded web site or to a linked web site, you may be asked to provide registration or other information. Please note that any information you are providing is going to a third party and you should familiarize yourself with the privacy policy provided by that third party.

Personal information (Non-Public)

In the event visitors to our web site choose to provide IKON with non-public personal information about themselves (e.g., name, address, phone number, email address) for the purpose of receiving additional information about our products and services, or if you are a IKON client and we obtain from you or from other sources non-public personal information about you in the course of providing you with our products and services, we will take the following steps to safeguard such non-public personal information (“Personal Information”).

Information We Collect

In order to provide you with financial products and services, or information about such services, IKON may collect the following types of Personal Information:

Information we receive from your Introducing Broker (if applicable) or from you on account applications, whether written or electronic, or on other forms (including on-line forms) and every time you email us or provide us with your details in other ways (i.e. over the telephone, by fax, by mail etc.) . This information would include, but not be limited to, such details as: your name, address, landline or mobile telephone numbers, fax number, e-mail address, social security or national insurance number, your date of birth; company name and contact details; income, investment experience; details of the ways in which you are happy to receive information from us and/or selected third parties etc.
Information about your transactions with us, our affiliates, or others. This information could include your trading history through us, our affiliates and others, your history of meeting margin calls, and your use of the various products and services that we and our affiliates provide.
Information about you obtained in connection with our efforts to protect against fraud or unauthorized use of your account(s) with us.
Information automatically collected about your visit to our Web site.
Information relating to your selection of a user ID for the use of some of our services or activities.
You will find that it is not compulsory to provide us with any additional information we request which is not necessary or reasonable in order to provide you with the services you have requested.

Use of Information Collected

We hold your personal information in order to open and manage your account with us, whilst also satisfying the key regulatory obligation of “Know your client”. In addition this information will enable us to review your needs on a regular basis thereby assisting us in providing you with the level of customer service you expect. It may also be used to provide you with new information or opportunities from us about our various products and services that we believe may be relevant to your needs.

Information We May Disclose

The personal information you provide may be accessed by or given to our staff and disclosed to unaffiliated third parties with which IKON is engaged in a joint marketing arrangement (see Who we may share your information with section below). The personal information disclosed to such unaffiliated third parties will include but not be limited to:

Information we receive from your Introducing Broker (if applicable) or from you on account applications, whether written or electronic, or on other forms (including on-line forms) and every time you email us or provide us with your details in other ways (i.e. over the telephone, by fax, by mail etc.) . This information would include, but not be limited to, such details as: your name, address, landline or mobile telephone numbers, fax number , e-mail address, social security or national insurance number, your date of birth; company name and contact details; income, investment experience; details of the ways in which you are happy to receive information from us and/or selected third parties etc.
Information about your transactions with us, our affiliates, or others. This information could include your trading through us, our affiliates and others, your history of meeting margin calls, and your use of the various products and services that we and our affiliates provide.
Who we may share your information with

IKON may disclose the types of Personal Information listed above (see Information we may disclose section above) to the following types of third parties:

Companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements to sell IKON products or services;
Financial service providers, such as introducing brokers, broker-dealers, futures commission merchants, investment companies, investment advisers, commodity trading advisors, and commodity pool operators;
Publishers and other direct marketers of products related to the financial services industry, such as newsletter or book publishers and software or trading system developers;
Government bodies and law enforcement agencies;
Successors in title to our business;
We may also disclose Personal Information to other non-affiliated third parties as permitted or required by law, such as in response to a subpoena or legal process or in order to complete a transaction which you initiated and authorised,
You should be aware that countries outside the European Economic Area do not always have strong data protection laws. Therefore However In the event any transfer data is made to countries outside of the EEA, this will only be done to; countries with equivalent legislation and or organisations with the appropriate level of data security.

Finally, if our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners.

Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.

Accessing, Updating , Contacting Us and Your right to opt-out of information sharing

Under the Data Protection Act 1998, you are entitled to see the personal information we hold about you and you may ask us to make any necessary changes to ensure that it is accurate and kept up to date.

Furthermore, if you prefer that we not disclose your Personal Information to unaffiliated third parties, you can choose to opt out of those disclosures. That is, you may direct us not to make those disclosures (other than disclosures permitted or required by law). However, this opt out will not apply to Personal Information disclosed about you to your Introducing Broker (if applicable), or any service provider necessary to effect or process any transaction in your account(s) with us (if applicable).

If you:

wish to correct or update the personal information that you have provided to us;
choose to opt out of any communications that you may have initially agreed to receive;
wish to opt out of disclosure to non-affiliated third parties; or if you
have any comments, queries or requests relating to our use of your personal information or any questions about this privacy policy, please contact info@ikonatlantic.com
We welcome your questions and any suggestions you may have about our privacy policy. However, we are entitled by law to charge a small administrative fee to meet our costs in providing you with details of the information we hold about you and we may require proof of your identity before we supply the information to you.

Online Services

If you register for any of our online products or services, we will retain your user ID and password and other information about your use of our web site in order that we may recognise you as a registered user. We may also obtain your email address from you or from another source. We may send you email offers for our as well as our affiliates’ products and services. You may also receive emails from third party product and service providers we think may be of interest to you. All email offers we send to you include an opportunity to opt out from future email offers.

If you opt out from receiving email offers, we reserve the right to still send (via email or otherwise) important information about your account(s) with us (if applicable) and our products and services.

Website Privacy Statement Updates

As and when necessary we reserve the right to make changes to our Privacy Statement. We recommend that regular visitors to our web sites review this Web site Privacy Statement periodically to learn of any updates and changes that have been made to this Statement. Should you become a IKON client by obtaining a user ID and password by completing account forms on-line, we will notify you of any changes we make to this Statement in the following manner. The first time you log on to a non-public part of our web site after we have modified our Web site Privacy Statement, you will be required to click-through our revised Statement. Accessing your account information or placing an order will not be possible until you agree to the terms of the revised Statement

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