It is the policy of Energy Capital to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities.
Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets.  Generally, money laundering occurs in three stages.  Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s checks, or deposited into accounts at financial institutions.  At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin.  At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.  Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.

• Establish and implement policies and procedures that can reasonably detect and cause the reporting of transactions as required by the rules and regulations listed below;

• Establish and implement policies, procedures and internal controls reasonably designed to achieve compliance with the Bank Secrecy Act;

• Provide for independent testing for compliance to be conducted by Company personnel or qualified outside parties;

• Designate an individual responsible for implementing and monitoring the day-to-day operations and internal controls of the program; and Provide ongoing training for personnel.