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Gleacher & Company Securities, Inc. – Anti-Money Laundering Policy Statement 

Gleacher & Company Securities, Inc. is committed to conducting its business and operations with the highest ethical standards and in full conformity with the anti-money laundering (AML) regulations and statutes. Money Laundering is the process used to transform cash or other funds generated from illegal activities into legitimate financial institutions or businesses to conceal the initial source of the funds or to create assets that appear to come from legitimate sources. In addition, terrorist activities have added another dimension to money laundering whereby funds (whether legally created or not) are used to fund illegal activities.
 
Gleacher & Company Securities, Inc. is also committed to knowing its customers and potential customers. This commitment and understanding is also necessary for Gleacher & Company Securities, Inc. and all its employees to avoid criminal liability as a result of customers using the resources of the institution for illicit purposes (i.e., money laundering and the funding of terrorist or criminal activity). Therefore, it is the responsibility of all Gleacher & Company Securities, Inc. employees to make all reasonable efforts to deter money laundering activities and determine the true identity of its customers and to maintain a clear understanding of its customers’ financial needs and practices.
 
Gleacher & Company Securities, Inc. has therefore developed an AML compliance program, which includes the following components:
Establishment of an effective and reasonable customer identification program (“CIP”) using documentary and non-documentary methods:


Internal policies, procedures, and controls designed to detect and deter money laundering and suspicious activities and report of such transactions to appropriate parties/agencies as required; designation of one or more qualified individuals responsible for implementing and monitoring the day-to-day operations and internal controls of the program; sharing information with other financial institutions; independent audit of AML program by an outside party; ongoing AML training for appropriate Gleacher & Company Securities, Inc. personnel.

 

Please contact Brian McDonagh at 212.273.7182 with questions regarding Gleacher & Company Securities, Inc.’s AML program.