July 2017

Interactive Brokers Asset Management’s Anti-Money Laundering Program

Covestor Ltd doing business as Interactive Brokers Asset Management (referred to thereafter as “IBAM”) is an investment adviser registered with the Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940. Registration with the SEC does not imply any level of skill or training.

IBAM has established and continues to maintain an Anti-Money Laundering Program reasonably designed to ensure that IBAM is in compliance with all applicable laws, rules and regulations related to anti-money laundering and anti-terrorist financing initiatives. Among other relevant laws, IBAM’s Anti-Money Laundering Program adheres to pertinent provisions of the USA PATRIOT Act, which prohibits accounts with foreign shell banks; requires financial institutions to conduct enhanced scrutiny of certain accounts maintained by or on behalf of senior foreign political figures.

More specifically, IBAM’s Anti-Money Laundering Program provides for:

  • A Customer Identification Program, and a system of internal controls to ensure that appropriate due diligence, and when necessary, enhanced due diligence, including obtaining and maintaining proper documentation, is conducted at account opening and updated, as necessary, throughout the course of the customer relationship;
  • The designation of an Anti-Money Laundering Compliance Officer responsible for coordinating and monitoring day-to-day compliance with the Anti-Money Laundering Program and applicable Bank Secrecy Act (“BSA”) laws, rules and regulations;
  • Recordkeeping and reporting practices in accordance with applicable laws, rules and regulations, including the BSA;
  • Appropriate methods of monitoring transactions and account relationships to identify potential suspicious activity;
  • Reporting of suspicious activity to governmental authorities in accordance with applicable BSA laws, rules and regulations;
  • Training of specific personnel with regard to anti-money laundering and anti-terrorist financing issues and their responsibilities for compliance; and
  • An independent review to ensure that the Anti-Money Laundering Program and applicable BSA laws, rules and regulations have been implemented and continue to be appropriately maintained.

IBAM relies on its affiliate, Interactive Brokers LLC, the qualified custodian for its client accounts, to perform certain aspects of its Anti-Money Laundering Program.