AML Policy

Omni Metal Investments

Tim Owens/ Harley Schnell


Responsible Office: Omni Metal Management

Origination Date: July 1, 2018

Last Amended Date: January 8, 2019


Anti-Money Laundering Policy

Policy Statement

It is the policy of Omni Metal Investments to comply with anti-money laundering obligations imposed by the federal government, including applicable provisions of the Money Laundering Control Act of 1986, the Bank Secrecy Act, the USA Patriot Act of 2001, the rules and regulations overseen by the United States Treasury Department’s office of Foreign Assets Control and Financial Crimes Enforcement Networks, and other legal requirements.


Reason for Policy/ Purpose

The purpose of this policy is to enhance Omni Metal Investments compliance with anti-money laundering laws and regulations, to assist law enforcement in combating illegal money laundering, and to minimize risk of Omni Metal Inv. Resources being used for improper purposes. Failure to comply with anti-money laundering regulations could result in civil and criminal penalties to Omni Metal Inv. And/or individual faculty, staff.


Who Needs to know this is Policy

Faculty and Staff


Table of Contents                                                                                      Page#

Policy statement                                                                                                                       1

Reason for policy/purpose                                                                                                      1

Who needs to know this policy                                                                                             1

Table of contents                                                                                                                      1

Policy/Procedures                                                                                                                     2

Website address for this policy                                                                                             2

Contacts                                                                                                                                      2

Related information                                                                                                                 3

Who Approved this Policy                                                                                                      3

History/Revision Dates                                                                                                            3








Money laundering is conduction or attempting to conduct a financial transaction knowing that the transaction is designed in whole or in part to conceal or disguise the nature, locations, source, ownership, or control of the proceeds of specified unlawful activity. TO assist the federal government in detecting, preventing, and eradicating criminal and terrorist financing and activity, the Omni Metals Inv.


Will take all necessary steps to comply with applicable anti-money laundering laws and regulations.

Omni Metal will maintain an anti-money laundering program in accordance with the Bank Secrecy Act, as amended by the USA PATRIOT ACT, and other applicable federal laws and regulations. The program is reasonably designed to prevent Omni Metal Inv. Services from being used to facilitate money laundering and the financing of terrorist activities. The program includes the following

  • Procedures to verify customer identifications and retain necessary identifying and transactional information
  • A designated compliance officer to coordinate compliance with the program
  • Suspicious activity reporting procedures and documents retention guidelines for any suspicious activity reports and supporting documentation
  • Training and education of appropriate university personnel concerning their responsibilities under the program, including suspicious activity reporting
  • Independent review to monitor and maintain an adequate program

Concerns regarding transactions that are unusually large or that appear suspicious and questions regarding money laundering in general should be directed to the Omni Metal Inv. Treasury Management Office at 936-615-7833.


Website Address for the Policy



Subject                                               Contacts                                            Phone

Money Laundering                         Managements                                  936-615-7833




Related Information

Bank Secrecy Act, 12 U.S.C. §1951, et seq.

31 U.S.C. §5311, et seq.

31 C.F.R. Part 1010, 1022

Money Laundering Control Act of 1986, Public Law 99-570

USA PATRIOT Act of 2001, Public Law 107-5

A Brief Primer on Doing Business Abroad: U.S. Law that Aff ect G Activities

Compliance with Law when Conductions University Act


Who Approved this Policy

Tim Owens, Co-Owner and Founder

Harley Schnell, Co-Owner and Founder


History/Revision Dates

Origination Date: July 1, 2018

Last Amended Date: January 8, 2019

Next Review Date:  January 8, 2020