Compliance

Although not all GTP activities fall under the AML regulatory scheme of the United States, some of its activities do require compliance with certain laws and regulations because they resemble a money transfer operation.   As such, GTP consents to regulatory oversight with respect to the followings laws:

  • The Currency and Foreign Transactions Reporting Act, also known as the Bank Secrecy Act 31 USC  5311-5330 and 12 USC 1818(s), 1829(b), and 1951-1959; and the BSA's implementing regulations, 31 CFR 103;
  • The USA Patriot Act of 2001, Public Law 107-56 as enacted October 26, 2001; The Anti-Money Laundering Law, 18 USC  1956;
  • The Prohibition of Unlicensed Money Transmitting Business 18 U.S.C.  1960:
  • The Treasury Department's Office of Foreign Assets Control ("OFAC") Rules and the Executive Orders Blocking Property and Prohibiting Transactions with Persons Who Commit, Threaten To Commit, or Support Terrorism, issued under the International Emergency Economic Powers Act; and
  • The Gramm-Leach-Bliley Act

In Compliance with those laws, GTP has implemented a comprehensive Anti-Money Laundering Program consisting of:

  • Employing a Certified Anti-Money Laundering Specialist (CAMS). The Company has designated E.R. "Chip" Albert for this position, who attends CAMS courses on a regular basis to ensure GTP is aware of any new laws, regulations, or compliance innovations.
  • Conducting regular anti-money laundering training for appropriate personnel
  • Submitting the AML program to an independent review to ensure its effectiveness
  • Implementing a Customer Identification Program ("CIP")
  • Implementing a Know Your Customer Program ("KYC"), including OFAC screening.
  • Implementing transaction monitoring tools to identify potential fraud or suspicious behavior (see Fraud Monitoring/Prevention, page 7).
  • Developing and applying a process to file required reports including Currency Transaction Reports and Suspicious Activity Reports
  • Ensuring all records are maintained for at least five years from the time those records are created.
  • Implementing a process to properly and timely report to government requests for information and subpoenas