About us

COOKIES POLICY 

WHO WE ARE

We are one of the leading business consultancy and brokerage firm and marketplace based in Michigan– USA.

Company Registered Name: MG Capital Group Inc.

Website Address: www.mgcgcorp.com

Our main office is located in 22167 Antler Drive, Novi, MI-48375. 

This Cookies Policy has been prepared in accordance with the provisions of the European General Data Protection Regulation (“GDPR”). 

COOKIES

Cookies are files sent by web servers to web browsers and stored by the web browsers and/or on your computer or mobile device that contains data related to a website you visit. It may allow a website “remember” your actions or preferences over a period of time, or it may contain data related to the function or delivery of the site. The information is then sent back to the server each time the browser requests a page from the server.  This enables a web server to identify and track web browsers. Cookies can be set by the owner of the website or in some cases by third party services the website owner allows to present other information, run content or provide other functionality such as analytics.

COOKIE USAGE ON OUR SITE/S

When you first visit this website, you will see a message informing you about cookies. If you click the ‘Hide this message” or “I agree” button, a cookie will be set that records your preference. Most browsers allow you to turn off cookies or to customize your settings for cookies. To find out how to do this, learn the “managing cookies in your browser”. Please note that if you turn off cookies or change your settings, some features of the website may not work correctly.

ABOUT COOKIES

This website uses cookies.  By using this website and agreeing to this policy, you consent to MG Capital Group Inc.  use of cookies in accordance with the terms of this policy.

GOOGLE COOKIES

We use Google Analytics to analyze the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on user’s computers.  The information generated relating to our website is used to create reports about the use of the website. Google will store and use this information.  Google’s privacy policy is available at: http://www.google.com/privacypolicy.html.

THIRD PARTY COOKIES

When you use this website, you may also be sent the third-party cookies, which may be used as per their policy and terms & conditions.

DISCLAIMER

By clicking “Continue” or continuing to use our site, you acknowledge that you accept our Privacy Policy, Cookies Policy and Terms of Use. We also use cookies to provide you with the best possible experience on our website. You can find out more about the cookies we use and learn how to manage them in policy statement. Feel free to check out our policies anytime for more information.

PRIVACY POLICY: General Data Protection Regulation (“GDPR”)

MG Capital Group Inc.  is committed to protecting and respecting your privacy.

This privacy policy (together with our Disclaimer, Terms of Use and our Marketplace Policy and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting this site, you are accepting and consenting to the practices described in this policy.

This privacy policy applies to information we collect with regards to;

• People who visit our site.
• People who subscribe for any services or information on our website.
• Partners, affiliates, agents and anybody who works with us to provide the services mentioned on our website

This policy does not apply to any public area or third-party area of our Site or services. In the event you submit personal information to contact another member of the Marketplace, contact a seller about a Listing, create a listing, add a contact on a Listing, or post on our Site, such information becomes publicly available and we are not responsible for the personal information you choose to submit to these services, forums, listings, or persons.

GENERAL

This Privacy Notice sets out how MG Capital Group Inc.  (hereinafter referred to as “MG Capital” or “We”) processes data, whether on individuals (including personal data in respect of individuals who are clients, prospective clients, intermediaries or other third parties that MG Capital interacts with, or any individual who is connected to those parties) or otherwise. Where the data held are on individuals, this document also sets out the rights of those individuals in respect of that personal data.

This Privacy Notice has been prepared in accordance with the provisions of the European General Data Protection Regulation (“GDPR”).

WHO WE ARE

We are one of the leading business consultancy and brokerage firm and marketplace based in Michigan– USA.

Company Registered Name: MG Capital Group Inc.

Website Address: www.mgcgcorp.com 

Our main office is located in 22167 Antler Drive, Novi, MI-48375. 

We strive to protect personal data and apply high standards of conduct when it comes to privacy issues. We ensure that our employees / associates are provided with the appropriate training in order to handle personal data promptly and in accordance with the laws. Furthermore, we endeavor to ensure that any parties with whom we co-operate apply the same high standards when it comes to data protection and privacy as We do. We ensure to be equipped with highest level of professional etiquettes & code of ethics to maintain Client’s Data Privacy.

WHAT WE COLLECT

When you visit one of our offices, our internet website(s), our social media pages, our online / media advertising channels or our representatives in various exhibitions, events or seminars or when you call / e-mail us; we may ask you to provide us with certain information so that we can communicate with you about our products and services and can address your enquiries with full commitment and professionalism. You are not obliged to provide us with such information, but if you choose not to, you may miss out on market updates, news, events and special offers and certain services may not be available to you.

Occasionally we may receive information about you from other sources (such as credit reference agencies) which we will add to the information which we already hold about you.

The personal information we will ask you to provide is the following:

• Full Name
• Address
• Country of Residence
• Nationality
• Contact Number
• Email
• Age
• Ethnic Group
• Family Details
• Work Related Information

When you visit our Site, make any searches, enquiries, or anything of such nature, we may automatically collect the following information:

• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• Information about the full Uniform Resource Locators (URL) clickstream.
• products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the Site.

When anybody leaves reviews, or testimonials about us on our website, we may collect your information as well and use the same to post on our website or any other media, along with your name and personal details as well.

Our website is a public plat form, you should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us.

All credit/debit cards details and personally identifiable information will NOT be stored, sold, shared, rented or leased to any third parties.

HOW WE USE IT 

Here at MG Capital we take your privacy seriously and will only use your personal information in accordance with our Personal Data Protection Policy, in order to communicate with you about our services, ensure the continuous supply of the services and to improve the quality of our services.

The purposes for which we collect your personal information are as follows;

• To investigate and follow up on any comments, inquiries and complaints you may have and to resolve any disputes and problems which may have arisen with respect to the use of our services.
• To obtain feedback from you that will help us to improve and/ or further the provision of our facilities and services.
• To communicate with you about our services that may be of interest to you.
• To communicate with you about products and/or services of our affiliates that may be of interest to you.
• To inform you about promotional events, special offers, etc.
• To update you with our latest marketing and advertising campaigns.
• To contact you or approach you with promotional campaigns or marketing via email, SMS, calls, social media or any other applicable medium or resources.
• To enable us to perform our obligations towards you.
• To comply with a legal obligation to which we may be subject.
• Any other purpose specifically requested and/or agreed by you.

HOW LONG WE KEEP IT

Your information will be kept only for as long as required to fulfil the purposes for which it was collected, in accordance with our Data Retention Policy. After the applicable retention period, your personal data will be irreversibly destroyed unless destruction is prohibited for legal, regulatory or technical reasons.

Any personal data held by us for marketing and service update notifications will be kept by us until such time that you notify us that you no longer wish to receive this information. Please refer to our Data Retention Policy for more information on our personal data retention schedule.

Any requests for further information in relation to the continued processing of specific data and requests for destruction of data should be made to info@mgcgcorp.com 

CHANGES TO THIS PRIVACY NOTICE

MG CAPITAL keeps this Privacy Notice under review in order to ensure that it is in line with any changes to the laws relating to privacy and personal data. Any updates will be communicated to you promptly and shall also appear on the Firm’s website at www.mgcgcorp.com.

This Privacy Policy was last updated on August 1, 2019.

YOUR RIGHTS

Should you believe that any personal information we hold on you is incorrect or incomplete, you have the ability to request to see this information, rectify it or have it deleted by contacting us through our website.

In the event that you wish to complain about how we have handled your personal data, please contact MG Capital  Data Projection Officer at info@mgcgcorp.com or in writing at given address. We will then look into your complaint and work with you to resolve the matter.

If you still feel that your personal data has not been handled appropriately according to the law, you can contact the Office of the Commissioner for Personal Data Protection.

Contact:      +1-248-474-7056

Email:       info@mgcgcorp.com 

EMAIL/SMS/MMS Alerts Terms

By registering or subscribing to receive communications via Email. Short Message Service or Text (“EMAIL/SMS/MMS Alerts Service” or “Communications” ), you are agreeing to the terms and conditions of this Agreement (“Terms”) and the MG Capital Group Inc. website Terms of Use and Privacy Policy.

Authorization: You certify that you are authorized:

1. to enroll the designated mobile phone number or email address in the EMAIL/SMS/MMS Alerts Service, and
2. to incur any mobile message or data charges that may be incurred by participating in the EMAIL/SMS/MMS Alerts Service.

Subscribing to Communications: You may subscribe to EMAIL/SMS/MMS Alerts by entering and submitting your email and/or phone number in the provided submission form available on our website and our mobile application. By entering your email or phone number and completing the submission form, you consent to these terms and to receive email and / or text message communications from MG Capital Group Inc.as described herein. A text message will be delivered to the mobile number or an email in your inbox confirming your enrollment once you have submitted your phone number. You are responsible for managing the types of texts (whether SMS or MMS or Emails) you receive.

By subscribing to Communications and Alerts, you expressly consent and agree to accept and receive any communications via email or text message to your mobile device and to the cellular/mobile telephone number(s) that you provided to us. The information in any message may be subject to certain time lags and/or delays.

Frequency of Communication: The number and frequency of  EMAIL/SMS/MMS Alerts sent to your device depends on several factors including the number of recent posts or news matching your search criteria, and if you’ve asked for help or any consulting or services or support via text messaging or email.

To Stop Messages: Text STOP to (248) 662-5759- or reply STOP to any text message you receive or unsubscribe from email by replying to support@mgcgcorp.com or contact MG Capital Group Inc. Customer Service at the contact information listed on our website.

You consent that following such a request to unsubscribe, you will receive one (1) final confirmation from MG Capital Group Inc. confirming that you have been inactivated in our system. Please allow up to three (3) business days to process your request.

For Help: Text HELP to (248) 662-5759 for help, or reply HELP to any message, or visit www.mgcgcorp.com for Customer Service contacts.

Message, Voice and Data rates may apply. By participating in the EMAIL/SMS/MMS Alerts Service, you approve any such charges from your mobile carrier. Check your carrier’s plan for details. You acknowledge and agree that you are solely responsible and liable for obtaining, maintaining, and paying all charges related to your mobile device(s).

No Guarantee: MG Capital Group Inc.is not responsible for incomplete, lost, late, or misdirected messages or emails, including (but not limited to) undelivered messages resulting from any form of filtering by your mobile carrier or service provider or otherwise.

Use of Automated Dialing Technology: You acknowledge and agree that the EMAIL/SMS/MMS Alerts Service may be provided in some cases through automatic telephone dialing technology, an artificial voice or a pre-recorded voice. By providing us your phone number, you expressly consent to receive the EMAIL/SMS/MMS Alerts Service through automatic dialing technology, artificial and pre-recorded voice.

General Communications: You agree to receive notifications from MG Capital Group Inc., its representatives, employees, and agents, through any means authorized under these Terms, including emails, phone calls and text messages that use automatic telephone dialing technology, artificial voice or pre-recorded voice, pre-set email campaigns or live person.

Termination: MG Capital Group Inc. reserves the right, in its sole discretion, to cancel or suspend any or all of the EMAIL/SMS/MMS Alerts Service, in whole or in part, for any reason, with or without notice to you.

Privacy Terms Attribution Corp Responsibility

MG Capital Group Inc.– All Rights Reserved

 DISCLAIMER

MG Capital Group Inc.is a private consulting firm and is not an Investment Advisor, Financial Agent or Broker, Tax Attorney, Legal Consultant or Immigration Attorney at Law. 

MG Capital Group Inc.is committed to use due diligence in furthering Client’s best interests and will and to provide unprejudiced specialized services with best of its knowledge, skills and expertise, undivided loyalty uncompromised by conflicts of interests and maintain professional code of conduct without any discrimination; however, MG Capital Group Inc. doesn’t extend any guarantee or warranty of the successful / desired outcome of the services / application. 

MG Capital Group Inc. doesn’t constitute any representation, warranty or guarantee of any kind whatsoever, and will not stand liable for any direct or indirect loss, loss of profit, personal / business opportunities, emotional disturbances, special or consequential damages arising out of or in connection with any delay in performance or non-performance, due to what so ever the reason may be.

MG Capital Group Inc. makes every effort to ensure that the information on its all marketing / advertising material, print collaterals, emails, website and service agreement is accurate and up-to-date with a sole purpose of education, reference and illustration and cannot be considered as an authoritative guide or reference on the latest business market and industry trends, also, we cannot and would not accept any obligation and responsibility for any errors, omissions, loss, damage or inconvenience caused by reliance on this content.

Any / all information about any investment opportunity or business listing is directly received from the Entrepreneurs or Businesses on AS IS basis which is deemed reliable but not guaranteed. We don’t verify or control any of such information. MG Capital Group Inc.is not responsible for and does NOT warrant any statements, projections or any information provided by the business or entrepreneurs. Investor’s will be solely responsible for authentication, verification and due diligence of any such information and business operations. 

By reviewing and signing this disclaimer, User confirms and understands that MG Capital Group Inc. has NOT performed an independent investigation of the business or figures quoted during mergers or acquisition process. We strongly recommend that a Buyer or Sellers should seek legal and accounting advice prior to finalizing any Business transaction.

Any of the user on this website also acknowledges, that he/she fully understands and acknowledges the fact the MG Capital Group Inc.is the legal owner of this website and portal and is a business brokerage and management consultancy firm who charges the management fee, success fee, subscription fee and commission as per their own business model. MG Capital Group Inc. doesn’t take any responsibility of the content and its authenticity of whatsoever the nature may be for such third-party listings. 

We endeavor to keep the information on this site up to date and correct, but is not necessarily comprehensive, complete, accurate or up to date hence we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, products, services, or related graphics contained on the website for any purpose. Any reliance you place on such information is therefore strictly at your own risk.

LIMITATION OF LIABILITY

MG Capital Group Inc. doesn’t constitute and expressly disclaims any representation, warranty or guarantee of any kind whatsoever, whether express or implied, and will not stand liable for any direct or indirect loss, loss of profit, personal / business opportunities, emotional disturbances, special or consequential damages, conditions of merchantability, fitness for a particular purpose and non-infringement arising out of or in connection with any delay in performance or non-performance due to what so ever the reason may be. 

The duties, responsibilities and obligations of MG Capital Group Inc. towards any other party and / or to any third party are limited to the terms and conditions of its signed service agreement ONLY and in no scenario the compensation and / or indemnification can increase than the value of its earned fee as per the signed contract whether sued or settled.

SERVICE DELIVERY AND CONTINUITY POLICY

MG Capital Group Inc.is committed to provide a state-of-the-art services to fulfil its contractual obligation and to achieve the maximum satisfaction of its clients and is authorized to use any external resources including but not limited to other service providers, attorneys, solicitors, vendors, freelancers, locally or global outsource staff, independent contractors or any individual or organization on its own discretion for the successful execution and competition of the services. 

MG Capital Group Inc. works on pre-paid services model and it reserves the rights to cancel / withdraw or suspend any of its ongoing services due to delay in payment or non-payment of its services. 

MG Capital Group Inc. reserves the right to stop or terminate the continuity of its services or block the access of any one to access the services and subscriptions available online, even if paid (ongoing) services, at per its own discretion in respect to the Terms of Use also called as User Agreement. 

MG Capital Group Inc. will NOT deal, entertain or provide services to any of OFAC* sanctioned countries or any other restrictions as per law of Unites Stated of America. 

*OFAC administers a number of different sanctions programs. The sanctions can be either comprehensive or selective, using the blocking of assets and trade restrictions to accomplish foreign policy and national security goals.

TERMS AND CONDITIONS: USER AGREEMENT 

By inquiring about our services, signing our retainer / service agreement, hiring our professional / management services, visiting our website / office/s, and accessing the information, knowledge, procedure, resources, services, products, and tools we provide, you understand and agree to accept and adhere to the following terms and conditions as stated in this policy (hereafter referred to as ‘User Agreement’). 

These Terms and Conditions are subject to change at the sole discretion of MG Capital Group Inc.without any prior notice. You acknowledge and agree that it is your responsibility to review this User Agreement (available on our website) periodically to familiarize yourself with any modifications. Your continued use of our site/services after such modifications will constitute acknowledgment and agreement of the modified terms and conditions and that MG Capital Group Inc., its directors, management, owners, officers, or employees are not responsible for any loss, damages, legal consequence, or anything that may result from the use of the site or its services.

GENERAL TERMS & CONDITIONS

• All Information is believed to be reliable based on the current fact & figures but is not guaranteed as it is for reference/educational purpose only and cannot be considered as an authoritative guide. MG Capital Group Inc.cannot accept any obligation and responsibility for any risk, loss, damage or inconvenience caused by reliance on this content or any errors or omissions.
• Unless otherwise expressed, MG Capital Group Inc.expressly disclaims all warranties and conditions of any kind, whether express or implied, including, but not limited to the implied warranties and conditions of merchantability, fitness for a particular purpose and non-infringement.
• MG Capital Group Inc.doesn’t constitute any representation, warranty or guarantee of any kind whatsoever, and will not stand liable for any direct or indirect loss, loss of profit, personal / business opportunities, emotional disturbances, special or consequential damages arising out of or in connection with any delay in performance or non-performance due to what so ever the reason may be.
• MG Capital Group Inc.relies on an outside vendor for website hosting and some technology solutions. MG Capital Group Inc.is not responsible for any website downtime or service interruptions associated with any technology problem(s), Internet problem(s), or any other type of problem(s) and is in no way obligated to make monetary reimbursements or refunds for any reason.
• MG Capital Group Inc.s in no way providing any legal, accounting, or business advice relating to the purchase or sale of any business or franchise, the hiring of any service advertiser, or the purchase of any products advertised on the website or making any business investment or migration decisions. We strongly advice the users to consult with independent third parties prior to their engagement and commitment. 
• For advisory and consulting services, market research and analysis, all the data and information provided is mere for guidelines or reference purpose and cannot be considered as an authoritative guideline. MG Capital Group Inc.doesn’t take responsibility of its authenticity and the dependence or reliance on it in any form. 
• Non-compliance to standard procedures may result to Non-Claimable application suspension.
• Business listing or introduction services provided by MG Capital Group Inc.are provided “As Is”. Clients of any of these services, or “advertisers” are responsible for the information posted on the site and are responsible for monitoring and managing their own accounts. In no way is MG Capital Group Inc.responsible for this information. 
• MG Capital Group Inc.reserves the right to modify and re-classify any advertising listing on the site at any time by adding new industry related categories, removing industry related categories, or modifying or adjusting any other classifications system that defines where or how a user will find a listed company’s ads. These changes may alter the way a listing advertisement is found through the website’s various search functions and tools.
• MG Capital Group Inc.is in no way obligated to refund any money for any service rendered or purchases after the actual service has been activated or implemented.
• MG Capital Group Inc.use the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site or to audiences similar to people who have visited our site.
• All the content, logo, drafts, blogs, trademark, service marks, is the intellectual property of MG Capital Group Inc.. Any unauthorized reproduction is strictly prohibited.
• The use of the site, its content, listings, and any other area is strictly prohibited for our direct or indirect competitors, nor shall you provide, disclose or transmit any portion of the Site to any direct or indirect competitor of us. In case if you need to work with us, you need to choose our affiliate program and that is subject to approval. 
• You agreed and will be fully liable to indemnify and keep us indemnified against and all claims, liabilities, losses, damages, costs, and expenses of any kind or character, whether director or incidental, including without limitation court costs, reasonable attorneys’ fees, expert witness’ fees, interest, fees, and penalties incurred by us as a result of your use of this Site.
• MG Capital Group Inc.is a privately held single member limited liability company and is not regulated or affiliated by any financial services authority or other such regulatory body and you are strictly prohibited from offering any form of bonds, securities, collective investment schemes, financial advice or any similar such arrangements.
• If you place your listings as an affiliate, you may not display your phone number or email address on your Listing in any forms, and Investors, Buyers will be able to contact you through the enquiry form placed next to your Listing.
• MG Capital Group Inc.reserves the right to change, alter, amend suspend, terminate or cancel any / all of the referral program, affiliate program or partner program on its on discretion with or without any prior notice. 
• MG Capital Group Inc.reserves the right to immediately remove the content or complete listing form our marketplace / database, if it is deemed in appropriate to our terms and conditions. And in such case no refund will be processed.
• In the event of loss or damage to any essential documents received, MG Capital Group Inc.liability will be limited to the actual value of the passport and documents up to a maximum of $100 per paid application. MG Capital Group Inc.s accepts no liability for consequential loss.
• MG Capital Group Inc.doesn’t provide any kind of guarantee or warranty on positive outcome of any program whatsoever the case may be. 
• Immigration application processing times shown on promotional materials are standard / average processing times only and should be used as a reference guide only.
• MG Capital Group Inc.always suggest and advises the Client planning for migration; not to sell / vacate any property, leave employment or finalize business or personal matters of whatsoever nature until written advice or approval has been received from the respective authorities.
• Certain documentation required for an Immigration application may be valid for a certain period of time and become invalid thereafter (for example medicals, skills assessment results, police clearance reports). It is the client’s responsibility to ensure that the documentation provided to MG Capital Group Inc.s at the time of submitting a visa application are valid and within date.

THIRD PARTIES

• In the event that consultation/data/information provided by MG Capital Group Inc.is being relayed/transferred by you to any third party as a recommendation, please be advised that you do so at your own risk. 
• You agree that, you will not forward data/information, provided in confidence, by MG Capital Group Inc., to any third party without the former’s explicit consent. The Client indemnifies MG Capital Group Inc.against any loss, action, proceedings, costs, claims and damages which may have be caused directly or indirectly by a breach of the aforementioned obligations of the client under this Agreement, OR, ramifications caused by the reliance of any third party on advice/data/information given by the Client, which was derived directly or indirectly from MG Capital Group Inc.s.

DIGITAL SIGNATURE & CONTRACTS 

In accordance with the Uniform Electronic Transactions Act (UETA) and the Electronic Signatures in Global and National Commerce Act, or E-Sign (the Act) and other applicable local or state legislation regarding Electronic Signatures and Transactions, the MG Capital Group Inc.hereby expressly accept the use of electronic signatures as an additional (main) method of signing and/or initialing any Agreement between MG Capital Group Inc.and the concerning party, clients, agent, broker or any third party. The parties hereby agree that either party may sign electronically by using a digital signature service or the digital / electronic forms and agreements made available on this website. 

Any party entering into any agreement with MG Capital Group Inc.through its digital contract available on website confirms, agrees and acknowledges that any such digital contract are explicitly enforceable by law. 

AFFILIATES / THIRD PARTY SERVICES / REFERRALS

• You understand that MG Capital Group Inc.may pay a commission in the form of a referral fee to any organization that refers business to us, and by agreeing to these terms and conditions, you are acknowledging that we have disclosed these business and financial agreements to you. 
• In certain cases, MG Capital Group Inc.may receive royalties, commissions, referral fees and all marketing contributions from third parties where we refer our clients to external vendors that are not under the control of the MG Capital Group Inc.. MG Capital Group Inc.does not accept any liability or responsibility for the services provided by a third party. We do not endorse and shall not be held responsible or liable for any content, advertising, products or services on or available from such third parties / vendors. 
• Any dealings between you and any vendors / third party advertiser or merchant mentioned or linked to by means of a direct dealing, including payment for and delivery of products, services and any other terms, conditions, warranties or representations associated with such dealings, are made between you and the relevant vendor / advertiser or merchant. MG Capital Group Inc.will not be held responsible or liable for any loss or damage of any kind incurred as the result of any such dealings. 
• Investors and Clients under no circumstances is allowed to have any sort of direct dealing with the Entrepreneurs / Sellers / vendors / attorneys / third parties introduced by MG Capital Group Inc.. And if he/she makes any sort of direct link / deal, MG Capital Group Inc.s will have a right to claim for the full amount of service fee equivalent to the value of services asked and also may include extra penalty charges levied by MG Capital Group Inc.s Management. 

GENERAL TERMS AND CONDITIONS FOR WEBSITE

By reading and continuing to use the site you agree to the following conditions of use.

1.  Disclaimer; MG Capital Group Inc.makes every effort to ensure that the information on this website is accurate and up to date. However, we cannot accept responsibility for any loss or inconvenience caused by reliance on inaccurate material contained in its website.

2.  Links to Other Sites; certain links, including hypertext links, in our site will take you outside our site to sites owned and operated by third parties. Links are provided for your convenience and inclusion of any link does not imply endorsement or approval by MG Capital Group Inc. of the linked site, its operator or its content. We are not responsible for the content of any website outside of our site. 

3.  Privacy Policy; MG Capital Group Inc. is dedicated to keeping your details private. Any information, we collect in relation to you, is kept strictly secured. We do not pass on/sell/swap any of your personal details with anyone. We use this information to identify your orders, provide you with our monthly newsletter (if applicable) and to personalize your service experience with us; that’s all. 

4.  Accessibility; MG Capital Group Inc. endeavors at all times to make the site as accessible as possible to disabled users. In no way does MG Capital Group Inc. seek to deliberately discriminate against disabled users’ access to the website service.

5.  Disputes and Jurisdiction; each provision within the terms and conditions are severable and any provision which is void, or could render the terms and conditions void, is excluded. The terms and conditions are governed by the law in force in United States of America and each party agreeing to the terms and conditions submits to this. Also, by agreeing to the terms and conditions you waive any claim that such courts are an inconvenience.

SUMMARY OF TERMS

Browser: Used to locate and display Web pages via a software application. The most popular ones are Microsoft Internet Explorer and Mozilla Firefox.

Cookie: Message given to a web browser by a web server. The message is then stored by the browser in a text file called ‘cookie.txt’. Cookies are used to enable a website to ‘remember’ whether a user has visited the site before and possibly to store marketing information about previous visits (items bought last time; pages visited etc.). Cookies are also used to store temporary information as a user moves from page to page within a site (items in a shopping basket etc.). Such cookies are erased when the user session ends. This information is converted to number format for statistical purposes, and all information relating to the individual is erased when the user session is ended. Users can set their browser not to allow cookies to be stored in their computer. To do this, please follow the instructions provided with your web browser software.

IP Address: If you are connected to the Internet you have one, for example it may look something like this 198.184.98.9

User Session: A user’s visit to a site begins when the user first accesses any page on a given site and ends after a visitor has left that site and not revisited it within a specified amount of time (normally 20 minutes) or when the user’s browser is closed.

Web Server: Delivers (serves up) web pages to your computer.

COPYRIGHT

All Content published on or otherwise accessible through this Website is protected by copyright. The Content, the copyright in the Content, and all other intellectual property relating thereto, are owned or controlled by MG Capital Group Inc.. You may only use or reproduce the information in the Content for your own personal, non-commercial or educational use. The Content may not be otherwise used, reproduced, broadcast, published or retransmitted without the prior written permission of the copyright holder. You must abide by all copyright notices, information and restrictions contained in any Content on or accessed through the Website and maintain such notices in the Content.

Refund Policy 

In an un-fortunate scenario, where the refund of the amount is claimed, MG Capital Group Inc strict Refund Policy is given as below;

• MG Capital Group Inc is a services-based consulting firm and is fully eligible to be compensated against its time, experience, expertise, advisory, consulting and services. Any amount earned in its scope of services is not refundable unless expressly declared. 
• Management Fee and Consulting Fee is treated as advance payment and considered as earned against the time and services of the Consultant, except the termination of the agreement for cause where;
  • If the premature termination is happening prior to rendering the full services, then a fair calculation will be made as per professional services rate along with any reimbursements and the portion of the unearned amount will be refunded to the Client. 
  • If the full scope of services is completed, Client might not be eligible for any refund.
• Any third-party payments including but not limited to investment amount, govt. / authority fee, third party payment, attorney fee, vendor payment is out of the scope of responsibility of MG Capital Group Inc and any refund is subject to their independent policy without any prejudice of MG Capital Group Inc. 
• Full refund will be issued in case of technical error such as double charging or any other cases where MG Capital Group Inc are responsible.
• A refund claim is acceptable in case of the inability or incompetency of service execution and in which case a fair calculation of compensation against the time and efforts must be evaluated. 
• Refund will be issued through the Original Mode of Payment or via Bank Transfer or Check where it is not possible to refund via the original mode of payment.
• Any success fee, referral fee, brokerage fee, commission or repatriation once earned is not refundable. 
• In any particular service request, the refund policy stated and described in its service contract is considered as annex to this refund policy and is enforceable. 
• Any refund request should be made in written email / letter form stating the exact reason of Refund claim which will immediately lead to suspension or termination of services. 
• Any refunds requested due to a customer error will be subject to a $ 350 administration charge, once approved. 
• Any refund once approved, will be processed within 30-45 working days.

MODE OF PAYMENT

For an ease of our valuable clients, MG Capital Group Inc offer multiple payment options given as below;

• Pay by Cheque –
  • Cheques issued under the name of “MG Capital Group Inc.” can be dropped to our office.
  • We can arrange for a pickup as per your convenience.
• Pay by Cash – Cash dealing is only allowed with the premises of MG Capital Group Inc – Michigan office in exchange with the company receipt only.
• Online Bank Transfer – Bank Transfer, ACH and Wire (Cash / Online) coming soon. We still can generate invoice for you which you can pay via bank transfer/wire.
• MG Capital Group Inc is not responsible for any direct / cash / un-authorized payment to any of its representatives (direct /indirect).
• MG Capital Group Inc provides its clients to pay online through its company website (www.mgcgcorp.com) via Credit card/Debit Card. An extra amount of 4% will be charged in case of credit card transaction as Bank Fee. An Invoice can be generated and emailed it to you with the payment link by which you can pay the Invoice amount.

For any further explanation / discussion, please feel free to contact our hotline +1-248-462-2353

Anti-Money Laundering (“AML”), Countering the Financing of Terrorism (“CFT”) and Know Your Client (“KYC”) Policy

1. MG Capital Group, Inc. (“MGCG, we, us, our”) Policy
It is the policy of MGCG to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the financing of terrorist or criminal activities.  We will comply with all applicable requirements and regulations.  Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have 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 either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.  Our AML/CFT policies, procedures and internal controls are designed to ensure compliance with all applicable regulations and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.

2. AML/CFT Compliance Person Designation and Duties
We have a designated Money Laundering Reporting Officer (“MLRO”).  The MLRO has full responsibility for our AML/CFT program. The duties of the MLRO will include monitoring our compliance with AML/CFT obligations, overseeing communication and training for employees and overseeing software modifications to ensure they comply with AML/CFT obligations. The MLRO will also ensure that we keep and maintain all of the required AML/CFT records and will ensure that any Suspicious Transaction Reports (“STR”) generated by our software are filed with the Financial Crime Unit (“FCU”) when appropriate. The MLRO is vested with full responsibility and authority to enforce our AML/CFT program. We will provide the company administrators, company secretary and associated financial institutions with contact information for the MLRO, including: (1) name; (2) title; (3) mailing address; (4) email address; and  (5) telephone number. We will promptly notify all parties of any change in this information and will review, and if necessary, update, this information within 30 business days after the end of each calendar year. The annual review of this information will be conducted by the MLRO and will be completed with all necessary updates being provided no later than 30 business days following the end of each calendar year. In addition, if there is any change to the information, the MLRO will update the information promptly, but in any event not later than 30 days following the change.

3. Giving AML/CFT Information to government authorities if requested
We will respond to a request (“Request”) concerning accounts and transactions by immediately searching our records to determine whether we maintain or have maintained any account for, or have engaged in any transaction with, each individual, entity or organization named in the Request. We will designate one or more persons to be the point of contact (“POC”) for Requests and will promptly update the POC information following any change in such information. (See Section 2 above regarding updating of contact information for the MLRO.) Unless otherwise stated in the Request, we are required to search our files for each individual, entity or organization named in the Request. If we find a match, the MLRO will consider any appropriate action. If the search parameters differ from searching through our entire database, for example, if limits to a geographic location apply, the MLRO will structure our search accordingly.  If the MLRO searches our records and does not find a matching account or transaction, then the MLRO will not reply to the Request. We will maintain a register of Money Laundering and Financing of Terrorism Enquiries together with documentation that we have performed the required search by saving the logs, which will at all times be available on request.  We will not disclose the fact that the authorities have requested or obtained information from us, except to the extent necessary to comply with the Request. The MLRO will review, maintain and implement procedures to protect the security and confidentiality of requests from the authorities with regard to the protection of customers’ non-public information.  We will direct any questions we have about the Request to the authorities.  Unless otherwise stated in the Request, we will not be required to treat the information request as continuing in nature, and we will not be required to treat the Request as a government provided list of suspected terrorists for purposes of the customer identification and verification requirements.

4. Levels of CDD
People who have opened an account need to provide their full contact details, prior to being allowed to deposit, trade and withdraw currencies.
This is known as Level 1 clearance, which allows deposits and withdrawals of USD 100 a day and USD 1,000 a month.
Level 2 clearance allows for USD 5,000 a day in deposits and withdrawals and USD 50,000 a month and for this a scanned copy of photographic ID and proof of address as explained in clause 5 is required.
Level 3 clearance allows for unlimited deposits and withdrawals and for this we will need original certified photographic ID and proof of address in our possession.

5. Customer Due Diligence (“CDD”) and Know Your Client Identification Program (“KYC”)
We will collect sufficient information from each customer who has opened an account to enable the customer to be identified; utilize risk-based measures to verify the identity of each customer who has opened an account; record CDD information and the verification methods and results; provide the required adequate CDD notice to customers that we will seek identification information to verify their identities; and compare customer identification information with government-provided lists of suspected terrorists, once such lists have been issued by the government.

a.  Required Customer Information
After opening an account, we will collect the following information for all accounts, if applicable, for any person, entity or organization that is opening a new account and whose name is on the account prior to activating the account for deposits and withdrawals of FIAT currencies (deposits, trading and withdrawing digital currencies does not require CDD verification):
1. the name;
2. date and place of birth (for an individual);
3. nationality;
4. gender;
5. email;
6. phone number;
7. proof of a residential address (for an individual), or a principal place of business, local office, or other physical location (for a person other than an individual); and
8. proof of identification with a photograph.

b. Customers Who Refuse to Provide Information
If a potential or existing customer either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, we will deactivate the account and, after considering the risks involved, consider closing any existing account. In either case, our MLRO will be notified so that we can determine whether we should report the situation to the authorities.

c. Verifying Information
Based on the risk, and to the extent reasonable and practicable, we will ensure that we have a reasonable belief that we know the true identity of our customers by using risk-based procedures to verify and document the accuracy of the information we get about our customers, but in any case complying with the statutory requirements. The MLRO will analyze the information we obtain to determine whether the information is sufficient to form a reasonable belief that we know the true identity of the customer (e.g., whether the information is logical or contains inconsistencies). We will verify customer identity through documentary means, non-documentary means or both. We will use documents to verify customer identity when appropriate documents are available. In light of the increased instances of identity fraud, we will supplement the use of documentary evidence by using the non-documentary means described below whenever necessary. We may also use non-documentary means, if we are still uncertain about whether we know the true identity of the customer. In verifying the information, we will consider whether the identifying information that we receive, such as the customer’s name, street address, postcode, email, telephone number, date of birth and photographic ID, allow us to determine that we have a reasonable belief that we know the true identity of the customer (e.g., whether the information is logical or contains inconsistencies). Appropriate documents for verifying the identity of customers include the following:

For an individual
– Proof of identity (passport copy or provisional or full driving licence or Government issued National Identity Card (picture page is sufficient))
– Proof of residential address (utility bill* less than 3 months old or bank statement) * Electricity, gas, water, phone bill (not mobile phone)

For a Corporation
– Certificate of Incorporation
– Memorandum and articles of Association
– Identify the Beneficial Owner
– For at least 2 directors of a Corporation – proof of identity and proof of residential address

All of the above documents should be certified by a lawyer, accountant, notary public or Consular Official at a British Embassy or Consulate for clearance level 3

The certifier must sign and date the copy document (printing his/her name clearly in capitals underneath) and clearly indicate his/her position or capacity on it and provide his contact details. The certifier must state that it is a true copy of the original. Any non-English documentation requires translation and certification as above.

We are not required to take steps to determine whether the document that the customer has provided to us for identity verification has been validly issued and that we may rely on a government-issued identification as verification of a customer’s identity. If, however, we note that the document shows some obvious form of fraud, we must consider that factor in determining whether we can form a reasonable belief that we know the customer’s true identity. We will use the following non-documentary methods of verifying identity:
– Confirming validity of email
– Confirming validity of telephone number
We will verify the information within a reasonable time after the account is opened. Depending on the nature of the account and requested transactions, we may refuse to complete a transaction before we have verified the information, or in some instances when we need more time, we may, pending verification, restrict the types of transactions or dollar amount of transactions. If we find suspicious information that indicates possible money laundering, terrorist financing activity, or other suspicious activity, we will, after internal consultation with our MLRO, report the activity in accordance with applicable laws and regulations.  We recognize that the risk that we may not know the customer’s true identity may be heightened for certain types of accounts, such as an account opened in the name of a corporation, partnership or trust that is created or conducts substantial business in a jurisdiction that has been designated as a primary money laundering jurisdiction, a terrorist concern, or has been designated as a non-cooperative country or territory. We will identify customers that pose a heightened risk of not being properly identified. We will also take the following additional measures that may be used to obtain information about the identity of the individuals associated with the customer when standard documentary methods prove to be insufficient:
1. Obtain verification of beneficial owners of corporations 
2. Obtain additional references from financial institutions

d. Lack of Verification
When we cannot form a reasonable belief that we know the true identity of a customer, we will do the following: (1) deactivate the account or keep it in deactivated status; (2) close an account after attempts to verify customer’s identity fail; and (3) determine whether it is necessary to inform the FSC or FCU in accordance with applicable laws and regulations.

e. Record keeping
We will keep logs of our verification, including all identifying information provided by a customer, the methods used and results of verification, and the resolution of any discrepancies identified in the verification process. We will keep records containing a description of any document that we relied on to verify a customer’s identity, noting the type of document, any identification number contained in the document, the place of issuance, and if any, the date of issuance and expiration date. With respect to non-documentary verification, we will retain logs that describe the methods and the results of any measures we took to verify the identity of a customer. We will also keep records containing a description of the resolution of each substantive discrepancy discovered when verifying the identifying information obtained. We will retain records of all identification information for five years after the account has been closed; we will retain records made about verification of the customer’s identity for five years after the record is made.

f. Comparison with Government-Provided Lists of Terrorists
At such time as we receive notice that the authorities have issued a list of known or suspected terrorists and identified the list as a list for CDD purposes, we will, within a reasonable period of time after an account is opened (or earlier, if required by another law or regulation or directive issued in connection with an applicable list), determine whether a customer appears on any such list of known or suspected terrorists or terrorist organizations issued by any government agency and designated as such by the authorities in consultation with the functional regulators. We will follow all directives issued in connection with such lists.

g. Notice to Customers
We will provide notice to customers that we are requesting information from them to verify their identities, as required by law. We will use the following method to provide notice to customers:
Inform them by email and through our software when the customer wants to activate their account for depositing and withdrawing FIAT currencies, by using the following text:

– Important Information About Procedures for Activating a New Account
To help the government fight the funding of terrorism and money laundering activities, we are required to obtain, verify, and record information that identifies each person who opens an account and wishes to deposit and withdraw FIAT currencies
– What this means for you: When you would like to deposit and withdraw FIAT currencies, we will ask for your name, address, date of birth and other information that will allow us to identify you. We will also ask to see photographic proof of your identification and proof of address.

h. Reliance on Another Financial Institution for Identity Verification
We may, under the following circumstances, rely on the performance by another party (including an affiliate) of some or all of the elements of our CDD with respect to any customer that is opening an account or has established an account or similar business relationship with the other party to provide or engage in services, dealings or other financial transactions:
– when such reliance is reasonable under the circumstances; and
– when the other party has entered into a contract with MGCG requiring it to certify annually to us that it has implemented its anti-money laundering and counter terrorist financing program and that it will perform (or its agent will perform) specified requirements of the CDD program.

6. General Customer Due Diligence
It is important to our AML and KYC reporting program that we obtain sufficient information about each customer to allow us to evaluate the risk presented by that customer and to detect and report suspicious activity. When we open an account for a customer, the due diligence we perform may need to be enhanced.  For each account meeting the following criteria and which could be deemed to be higher risk:
– Corporations in off shore jurisdiction;
– Individuals from high risk countries; and
– CDD documentation of questionable origin;
We will take steps to obtain sufficient customer information to comply with our  enhanced due diligence requirements. Such information should include:
– Identification of beneficial owners of corporations
– Reference from a financial institution
– Proof of source of funds.

7. Customer Due Diligence and Enhanced Due Diligence Requirements for Private Banking Accounts/Senior Foreign Political Figures
We do not open or maintain private banking accounts.

8. Monitoring Accounts for Suspicious Activity
We will monitor account activity for unusual size, volume, pattern or type of transactions, taking into account risk factors and red flags that are appropriate to our business. (Red flags are identified in Section 8.b. below.) The MLRO or his or her designee will be responsible for this monitoring, will review any activity that our monitoring system detects, will determine whether any additional steps are required, will document when and how this monitoring is carried out, and will report suspicious activities to the appropriate authorities.  The MLRO or his or her designee will conduct an appropriate investigation and review relevant information from internal or third-party sources before the authorities are notified.

a. Emergency Notification to Law Enforcement by Telephone
In situations involving violations that require immediate attention, such as terrorist financing or ongoing money laundering schemes, we will immediately call an appropriate law enforcement authority.
b. Red Flags

Red flags that signal possible money laundering or terrorist financing include, but are not limited to:
Customers – Insufficient or Suspicious Information

– Provides unusual or suspicious identification documents that cannot be readily verified.
– Reluctant to provide complete information about nature and purpose of business, prior banking relationships, anticipated account activity, officers and directors or business location.
– Refuses to identify a legitimate source for funds or information is false, misleading or substantially incorrect.
– Background is questionable or differs from expectations based on business activities.
– Customer with no discernible reason for using MGCG service.

Efforts to Avoid Reporting and Record keeping
– Reluctant to provide information needed to file reports or fails to proceed with transaction.
– Tries to persuade an employee not to file required reports or not to maintain required records.
– “Structures” deposits, withdrawals or purchase of monetary instruments below a certain amount to avoid reporting or record keeping requirements.
– Unusual concern with MGCG compliance with government reporting requirements and MGCG AML/CFT policies.

Certain Funds Transfer Activities
– Wire transfers to/from financial secrecy havens or high-risk geographic location without an apparent business reason.
– Many small, incoming wire transfers or deposits made using checks and money orders. Almost immediately withdrawn or wired out in manner inconsistent with customer’s business or history. May indicate a Ponzi scheme.
– Wire activity that is unexplained, repetitive, unusually large or shows unusual patterns or with no apparent business purpose.

Activity Inconsistent With Business
– Transactions patterns show a sudden change inconsistent with normal activities.
– Unusual transfers of funds or journal entries among accounts without any apparent business purpose.
– Maintains multiple accounts, or maintains accounts in the names of family members or corporate entities with no apparent business or other purpose.
– Appears to be acting as an agent for an undisclosed principal, but is reluctant to provide information.

Other Suspicious Customer Activity
– Unexplained high level of account activity with very low levels of securities transactions.
– Funds deposits for purchase of a long-term investment followed shortly by a request to liquidate the position and transfer the proceeds out of the account.
– Law enforcement requests.

c. Responding to Red Flags and Suspicious Activity
When an employee of MGCG detects any red flag, or other activity that may be suspicious, he or she will notify the MLRO. Under the direction of the MLRO, MGCG will determine whether or not and how to further investigate the matter. This may include gathering additional information internally or from third-party sources, contacting the government, freezing the account and/or informing the authorities.

9. Suspicious Transactions Reporting
a. Filing a report with the FSC or FCU

We will file a report with the authorities
for any transactions (including deposits and transfers) conducted or attempted by, at or through MGCG involving $10,000 or more of funds (either individually or in the aggregate) where we know, suspect or have reason to suspect: (1) the transaction involves funds derived from illegal activity or is intended or conducted in order to hide or disguise funds or assets derived from illegal activity as part of a plan to violate or evade law or regulation or to avoid any transaction reporting requirement under law or regulation; (2) the transaction is designed, whether through structuring or otherwise, to evade any requirements of the regulations; (3) the transaction has no business or apparent lawful purpose or is not the sort in which the customer would normally be expected to engage, and after examining the background, possible purpose of the transaction and other facts, we know of no reasonable explanation for the transaction; or (4) the transaction involves the use of MGCG to facilitate criminal activity.
We will also file a report and notify the appropriate law enforcement authority in situations involving violations that require immediate attention, such as terrorist financing or ongoing money laundering schemes. We may file a voluntary report for any suspicious transaction that we believe is relevant to the possible violation of any law or regulation but that is not required to be reported by us. It is our policy that all suspicious activities will be reported regularly to the Board of Directors and appropriate senior management.

b. Currency Transaction Reports
MGCG only allows FIAT currency transactions once accounts are activated. Any transfers over $10,000 may be reported to the authorities.

c. Currency Transportation
MGCG prohibits both the receipt of currency or other monetary instruments that have been transported, mailed or shipped to us.  MGCG only accepts currency transactions through financial institutions and internationally recognized payment platforms.

d. Monetary Instrument Purchases
We do not issue bank checks or drafts, cashier’s checks, money orders or traveller’s checks in the amount of $3,000 or more.

10. AML/CFT Record keeping
a. Responsibility for Required AML Records

Our MLRO and his or her designee will be responsible for ensuring that AML/CFT records are maintained properly. In addition, as part of our AML/CFT program, MGCG will create and maintain all relevant documentation on customer identity and verification (See Section 4 above) and funds transmittals. We will maintain all documentation for at least five years.

b. AML/CFT Reporting Maintenance and Confidentiality
We will hold reports and any supporting documentation confidential. We will not inform anyone outside of the authorities or other appropriate law enforcement or regulatory agency about a report. We will segregate report filings and copies of supporting documentation from other firm books and records to avoid disclosing information. Our MLRO will handle all requests for reports.We may share information with another institution about suspicious transactions in order to determine whether we will jointly file a report according to the rules and regulations of the authorities. In cases in which we file a joint report for a transaction that has been handled both by us and another institution, both institutions will maintain a copy of the filed report.

c. Additional Records
We shall retain either the original or a microfilm or other copy or reproduction of each of the following:
– A record of each advice, request or instruction received or given regarding any transaction resulting (or intended to result and later cancelled if such a record is normally made) in the transfer of currency or other monetary instruments, funds of more than $10,000;
– A record of each advice, request or instruction given to another institution (which includes broker-dealers) or other person, regarding a transaction intended to result in the transfer of funds, or of currency, other monetary instruments, of more than $10,000;
– Each document granting signature or trading authority over each customer’s account;
– A record of each remittance or transfer of funds, or of currency of more than $10,000 to a person, account or place; an
– A record of each receipt of currency and of each transfer of funds of more than $10,000 received on any one occasion directly and not through a domestic financial institution, from any person, account or place.

11. Clearing/Introducing Relationships
We will work closely with all collaborating institutions to detect money laundering. We will exchange information, records and data as necessary to comply with AML/CFT laws.

12. Training Programs
We will develop ongoing employee training under the leadership of the MLRO and senior management. Our training will occur on at least an annual basis. It will be based on our firm’s size, its customer base, and its resources and be updated as necessary to reflect any new developments in the law.  Our training will include, at a minimum: (1) how to identify red flags and signs of money laundering and/or the financing of terrorism that arise during the course of the employees’ duties; (2) what to do once the risk is identified (including how, when and to whom to escalate unusual customer activity or other red flags for analysis and, where appropriate, the filing of reports to the authorities; (3) what employees’ roles are in MGCG compliance efforts and how to perform them; (4) MGCG record retention policy; and (5) the disciplinary consequences (including civil and criminal penalties) for non-compliance with the FSC regulations.  We will develop training in our firm, or contract for it. Delivery of the training may include educational pamphlets, videos, intranet systems, in-person lectures and explanatory memos. We will maintain records to show the persons trained, the dates of training and the subject matter of their training.  We will review our operations to see if certain employees, such as those in compliance, margin and corporate security, require specialised additional training. Our written procedures will be updated to reflect any such changes.

13. Program to Independently Test AML /CFT Program
a. Staffing
The testing of our AML/CFT program will be performed at least annually (on a calendar year basis) by the testing officer, personnel of MGCG, who is not the MLRO nor does he perform the AML/CFT functions being tested nor does he report to any such persons. His qualifications include a working knowledge of applicable requirements under the FSC rules and regulations. To ensure that he remains independent, we will separate his functions from other AML/CFT activities. Independent testing will be performed more frequently if circumstances warrant.

b. Evaluation and Reporting
After we have completed the independent testing, staff will report its findings to an internal audit committee.  We will promptly address each of the resulting recommendations and keep a record of how each noted deficiency was resolved.

14. Monitoring Employee Conduct and Accounts
We will subject employee accounts to the same AML/CFT procedures as customer accounts, under the supervision of the MLRO. We will also review the AML/CFT performance of supervisors, as part of their annual performance review. The MLRO’s accounts will be reviewed by the testing officer

15. Confidential Reporting of AML/CFT Non-Compliance
Employees will promptly report any potential violations of MGCG AML/CFT compliance program to the MLRO, unless the violations implicate the MLRO, in which case the employee shall report to the testing officer. Such reports will be confidential, and the employee will suffer no retaliation for making them.

16. Additional Risk Areas
We have reviewed all areas of its business to identify potential money laundering and/or financing of terrorism risks that may not be covered in the procedures described above. The major additional areas of risk include future changes to regulations and hacking attempts on MGCG servers. Additional procedures to address these major risks are maintaining constant contact with the FSC and performing daily security checks on MGCG server security procedures, performed by a dedicated server security specialist.

17. Senior Manager Approval
Senior management has approved this AML/CFT compliance program in writing as reasonably designed to achieve and monitor our firm’s ongoing compliance with the requirements of the FSC and the implementing regulations under it.