eTrade 2011 Annual Report Download - page 187

International Anti-Boycott Laws
U.S. law and E*TRADE prohibit participation in boycotts against countries friendly to the United States. Furthermore, violations of
the anti-boycott provisions are a criminal offense. Examples of activities that may be perceived as participating in a boycott include
refusing, or requiring another person to refuse, to do business with a boycotted country, its business concerns, its residents or
nationals. E*TRADE may be required to report these requests, even though the request was refused. All employees are required to
bring such requests immediately to the attention of Legal.
Anti-Money Laundering and Anti-Terrorism Laws
U.S. Anti-Money Laundering (“AML”) laws aim to prevent, detect and deter money laundering and terrorist financing. The term
“money laundering” covers any process designed to conceal the true origin and ownership of the proceeds of criminal activities that
changes the identity of illegally obtained money so that it appears to have originated from a legitimate source. The term “terrorist
financing” covers activities that are ideological rather than profit-based, which can include providing, collecting or using funds –
whether legitimately or illegally obtained – to carry out a terrorist act.
It is E*TRADE’s policy to comply fully with all federal and state laws and the laws of other countries concerning the prohibition of
money laundering and safeguard against the financing of terrorist activity, such as the Bank Secrecy Act, including regulations issued
pursuant to the US Patriot Act of 2001; OFAC regulations; and related laws. To this end, employees must immediately report any
suspicious or unusual activity relating to any E*TRADE customer or employee to the appropriate AML Compliance Officer or
Corporate Security and Fraud Management.
In addition to severe criminal and civil penalties, violations of anti-money laundering laws will result in disciplinary action, including
possible termination, and any act by or on behalf of E*TRADE or its employees that assists in money laundering could be a serious
criminal offense. Failure to report suspicions of money laundering to the relevant authorities also may constitute an offense and could
involve significant penalties for E*TRADE, as well as the individuals involved. Finally, employees are prohibited from alerting a
customer or other E*TRADE employees (outside of those responsible for managing the situation) of your suspicion, as this may also
be an offense in certain jurisdictions. Each regulated entity has developed comprehensive policies and procedures with respect to anti-
money laundering. For specific policies and procedures applicable to your business unit, check with your AML Compliance Officer
or review the link below.
E*TRADE’s AML policies and procedures can be accessed on My Channel*E, as follows: Bank:
https://mychannele.corp.etradegrp.com/web/guest/departments/bankcompliance/policies (see Bank Secrecy Act Policy); and Non-
Bank (Brokerage; Clearing; Corporate): https://mychannele.corp.etradegrp.com/web/guest/departments/brokeragecompliance/wsp.
Intellectual Property Protection
Most jurisdictions offer some form of legal protection for intellectual property, including copyrights, patents, trademarks and trade
secrets.
Copyright laws govern the display and reproduction of copyrighted material, which includes most books, magazines, newspapers,
websites, research reports and software. You cannot display or reproduce copyrighted material without the permission of the
copyright owner. Because copyright laws are complex,
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