Table of Contents

1. Policy Statement

2.Objectives of the Firm’s Anti-Money Laundering Policies and Procedures

3. What is Money Laundering?

4. Anti-Money Laundering Compliance Officer

5.Anti-Money Laundering Employee Training Program

6. Client Identification Procedures

6.1. General
 6.2 Client Identification Procedures for Natural Persons
 6.3Client Identification Procedures for Corporations, Partnerships, Trusts and
Other Legal Entities
 6.4 High-Risk Clients
 6.4.1Enhanced Client Identification Procedures for ‘High-Risk’ Natural Persons
 6.4.2Enhanced Client Identification Procedures for ‘High-Risk’ Corporations,
Partnerships, Trusts and Other Legal Entities

7. Client Records Retention

8.Review of Existing Client Base and Detection of Suspicious Activity

9. Definitions

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Anti-Money Laundering Compliance Statement

 
1. Policy Statement

The company is committed to full compliance with all applicable laws and regulations regarding anti-money laundering procedures. We have adopted and will enforce the provisions set forth in our Anti-Money Laundering Compliance Manual in order to prevent and detect money laundering, terrorist financing and other illegal activities.

If the Firm, its personnel and/or premises are inadvertently used for money laundering or other illegal activities, the Firm can be subject to potentially serious civil and/or criminal penalties. Therefore, it is imperative that every member, officer, director, partner and employee (each, an “Employee”) is familiar with and complies with the policies and procedures set forth in this Compliance Manual.

This Compliance Statement is designed to assist all clients in adhering to the Firm’s policy and procedures, which, if followed diligently, are designed to protect themselves, the Firm, its Employees, its facilities and its activities from money laundering or other illegal activities.

To ensure that the Firm’s policies and procedures are adhered to, the Firm has designated an Anti- Money Laundering Compliance Officer (the “Compliance Officer”). The Compliance Officer is responsible for establishing and conducting Employee training programs to ensure that all appropriate Employees are aware of the applicable anti- money laundering laws and regulations, the Firm’s anti- money laundering policies and their responsibilities with respect to these policies.

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2.Objectives of the Firm’s Anti- Money Laundering Policies and Procedures

• Comply with all anti- money laundering rules and regulations of the jurisdictions it operates in;

• Require all Employees to prevent, detect and report to the Compliance Officer all potential instances in which the Firm or its Employees, its facilities or its activities have been or are about to be used for money laundering, terrorist financing and other illegal activity;

• Provide for a Compliance Officer who shall ensure adherence to the Firm’s anti-money laundering policies and procedures;

• Require all appropriate Employees to attend anti-money laundering training sessions, so that all such Employees are aware of their responsibilities under the Firm’s policies and procedures; this Compliance Manual; and as affected by current developments with respect to anti-money laundering events.
 

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3. What is Money Laundering?

Money laundering involves the placement of illegally obtained money into legitimate financial systems so that monetary proceeds derived from criminal activity are transformed into funds with an apparently legal source.

Money laundering has many destructive consequences both for society as a whole and for those entities involved in money laundering activities. With respect to society as whole, money laundering may provide resources for drug dealers, terrorists and other criminals to operate and expand their criminal activities.

With respect to entities, any involvement, whether it be to instigate, assist, conceal, or ignore the source, nature, location, ownership or control of money laundering activities, can lead to both civil and criminal proceedings against both the individual and the entity involved. Additionally, the adverse effects, including the adverse publicity to the Firm associated with involvement in money laundering events cannot be emphasized enough.

Money laundering transactions may include:

• Advising a potential or existing client on how to structure a transaction to avoid reporting and/or record keeping requirements;

• Engaging in any activity while willfully or recklessly disregarding the source of the funds or the nature of the Clients transaction;

• Engaging in any activity designed to hide the nature, location, source, ownership or control of proceeds of criminal activity;

• Dealing in funds to facilitate criminal activity; or

• Dealing in the proceeds of criminal activity.

Money laundering can involve the proceeds of drug dealings, terrorist activities, arms dealings, mail fraud, bank fraud, wire fraud or securities fraud, among other activities.

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4. Anti- Money Laundering Compliance Officer

Any Employee shall immediately notify the Compliance Officer if he/she suspects or has any reason to suspect that any potentially suspicious activity has occurred or will occur if a transaction is completed. Employees are encouraged to seek the assistance of the Compliance Officer with any questions or concerns they may have with respect to the Firm’s anti-money laundering policies or procedures.

Responsibilities of the Compliance Officer include the following:

• Coordination and monitoring of the Firm’s day-to-day compliance with applicable anti- money laundering laws and regulations and the Firm’s own anti-money laundering policy and procedures;

• Conducting Employee training programs for appropriate personnel related to the Firm’s anti-money laundering policy and procedures and maintaining records evidencing such training;

• Receiving and reviewing any reports of suspicious activity from Employees;

• Determining whether any suspicious activity as reported by an Employee warrants reporting to senior management of the Firm;

• Coordination of the annual audit of the training program and Compliance Manual; Coordination of enhanced due diligence procedures regarding Clients; and Responding to both internal and external inquiries regarding the Firm’s anti- money laundering policies and procedures.

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5.Anti-Money Laundering Employee Training Program

As part of the Firm’s anti- money laundering program, all Employees are expected to be fully aware of the Firm’s anti-money laundering policies and procedures.

Each Employee is required to read and comply with this Compliance Manual, address any questions and concerns to the Compliance Officer and sign the acknowledgement form confirming that he/she has read and understands the Firm’s anti-money laundering policies and procedures.

To ensure the continued adherence to the Firm’s anti-money laundering policies and procedures, all Employees are required to reconfirm their awareness of the contents of this Compliance Manual by signing the acknowledgement form annually, or more frequently, as required by the Compliance Officer.

All Employees are required, at a time specified by the Compliance officer, to undertake training programs on anti-money laundering policies and procedures.

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6. Client Identification Procedures

6.1. General

The Firm’s anti-money laundering policies and procedures are intended to ensure that, prior to accepting funds from Clients, all reasonable and practical measures are taken to confirm the Clients’ identities.

And to verify that any third party upon whom the Firm relies for Client identification, such as a bank or other financial intermediary, a placement agent, a consultant, or a fund-of- funds, or custodian, or nominee, or administrator, or any other third party adheres to the same standards.

These Client Identification Procedures are based on the premise that the Firm will accept funds from a new and existing Client only after:

• The Firm has confirmed the Client’s identity and that the Client is acting as a principal and not for the benefit of any third party unless specific disclosure to that effect is made; or

• If the Client is acting on behalf of others, the Firm has confirmed the identities of the underlying third parties.

The Client Identification Procedures should be reviewed in light of the specific characteristics presented by a Client and in any instance the Compliance Officer may determine to apply enhanced measures for reasons other than those discussed in section 6.4.

As a reference tool, an Individual Client KYC Checklist is used. Employees are encouraged to provide the Compliance Officer with any revisions they consider appropriate.

The Compliance Officer shall retain copies of all documents reviewed or checklists completed in connection with its Client Identification Procedures in accordance with the Firm’s Client Records Retention policies (see section 7).

6.2Client Identification Procedures for Natural Persons

The Firm shall take reasonable steps to ascertain satisfactory evidence of an individual Client’s name, address, date and place of birth, investment experience and objective, net worth, occupation, including the employer’s address and the source of the Client’s funds.

In order to confirm the identity of the Client, copies of certain of the following documents will be obtained and retained for the Firm’s records:

• Driver’s license, passport or other official government-issued identification; and

• Additional information which may be requested includes:

1. Bank statement or utility bill; or other residential identifying information;
2. Credit report; and/or
3. Personal/ bank references.

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6.3Client Identification Procedures for Corporations, Partnerships, Trusts and Other Legal Entities

The Firm shall take reasonable steps to ascertain satisfactory evidence of an entity Client’s name and address, its authority to make the contemplated investment, investment experience and objective and the source of funds.

The Firm will obtain certain of the following, as appropriate under the circumstances:

• Evidence that the Client has been duly organized in its jurisdiction of organization;

• Copy of resolution granting the Directors/Principals/Partners authority to act;

• List of Directors/Principals/Partners, including background information;

• Original authorized signatory list;

• Description of the Client’s primary lines of business;

• Publicly available information from law enforcement agencies or regulatory authorities; and/or

• Client’s annual report and/or, if appropriate, Client’s bank references.

6.4 High-Risk Clients

The Compliance Officer provides and will continuously update a list of the types of Clients the Firm considers to be of ‘high risk,’ such that enhanced due diligence procedures are warranted compared to the routine Client Identification Procedures.

Tax havens consider the following Clients to pose a high money laundering risk (see Appendix A for definitions):

• A Senior Foreign Political Figure, any member of a Senior Foreign Political Figure’s Immediate Family, and any Close Associate of a Senior Foreign Political Figure;

• Any Client resident in, or organized or chartered under the laws of, a Non-Cooperative Jurisdiction;

• Any Client who gives the Compliance Officer any reason to believe that its funds originate from, or are routed through, an account maintained at an “offshore bank”, or a bank organized or chartered under the laws of a Non-Cooperative Jurisdiction; and

• Any Client who gives the Compliance Officer any reason to believe that the source of its funds may not be legitimate or may aid terrorist activities.

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6.4.1Enhanced Client Identification Procedures for ‘High-Risk’ Natural Persons

• Enhanced Client Identification Procedures for ‘high risk’ natural persons as Clients include, but are not limited to, the following:

• Assessing the Client’s business reputation through review of financial or professional references, generally available media reports or by other means;

• Considering the source of the Client’s wealth, including the economic activities that generated the Client’s wealth, and the source of the particular funds intended to be used to make the investment;

• Reviewing generally available public information, such as media reports, to determine whether the Client has been the subject of any criminal or civil enforcement action based on violations of anti-money laundering laws or regulations or any investigation, indictment, conviction or civil enforcement action relating to financing of terrorists;

• Reviewing the Client’s last tax return, financial statements and/or bank statements; and

• Conducting a face-to-face meeting with the Client to discuss/confirm the account opening documents, purpose of account and source of assets.

The enhanced due diligence procedures undertaken with respect to ‘high risk’ Clients must be thoroughly documented in writing, and any questions or concerns with regard to a ‘high risk’ Clients should be directed to the Compliance Officer.

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6.4.2Enhanced Client Identification Procedures for ‘High-Risk’ Corporations, Partnerships, Trusts and Other Legal Entities

Enhanced Client Identification Procedures for ‘high risk’ corporations, partnerships and other legal entities include, but are not limited to, the following:

• Assessing the Client’s business reputation through review of financial or professional references, generally available media reports or by other means;

• Reviewing recent changes in the ownership or senior management of the Client;

• Conducting a visit to the Client’s place of business and conducting a face- to-face meeting with the Client to discuss/confirm the account application, the purpose of the account and the source of assets;

• If applicable, determining the relationship between the Client and the government of its home country jurisdiction, including whether the Client is a government-owned entity; and

• Reviewing generally available public information to determine whether the Client has been the subject of any criminal or civil enforcement action based on violations of anti-money laundering laws or regulations or any criminal investigation, indictment, conviction or civil enforcement action relating to financing of terrorists.

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7. Client Records Retention

Copies of all documents related to the Firm’s Client Identification Procedures will be retained for an appropriate period of time and, at a minimum, the period of time required by applicable law or regulation.

The documents the Firm retains are copies of documents reviewed in connection with Client Identification Procedures or enhanced due diligence procedures, Client identification checklists, if any, or similar due diligence documentation, and any other documents required to be retained by applicable anti-money laundering legislation.

The Firm will retain documents for so long as a Client is a client of the Firm and for a minimum of five years after this relationship ends.

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8.Review of Existing Client Base and Detection of Suspicious Activity

The Compliance Officer shall coordinate a periodic review of the Firm’s existing Client list, and ensure the adequacy of due diligence performed on existing Clients.

In addition, the Firm’s policies, procedures and controls may provide for the detection of suspicious activity, and if detected may require further review to determine whether the activity is suspicious, as described below.

For example, in some circumstances, the following activities, none of which per se constitutes suspicious activity, may be indicative of activity that may require further investigation:

• Client exhibits an unusual concern regarding the Firm’s compliance with government reporting requirements, particularly with respect to the Client’s identity, type of business and assets, or the Client is reluctant or refuses to reveal any information concerning business activities, or the Client furnishes unusual or suspect identification or business documents;

• Client wishes to engage in investments that are inconsistent with the Client’s apparent investment strategy;

• Client (or a person publicly associated with the Client) is the subject of news reports indicating possible criminal, civil or regulatory violations;

• Client appears to be acting as the agent for another entity but declines, or is reluctant, without legitimate commercial reasons, to provide any information in response to questions about such entity;

• Client has difficulty describing the nature of his or her business or lacks general knowledge of the industry he or she is apparently engaged in;

• Client attempts, with unusual frequency (taking into account the differences between Clients and Intermediaries as appropriate), to make investments, redemptions/withdrawals, or transfers;

• Client engages in unusual or frequent wire transfers (taking into account the differences between Clients and Intermediaries as appropriate), particularly to unfamiliar bank accounts;

• Client transfers funds to jurisdictions other than its home jurisdiction; and

• Client attempts to make or requests transactions in cash or cash equivalents.

The Firm requires any Employee who detects suspicious activity or has reason to believe that suspicious activity is taking place immediately to inform his or her immediate supervisor as well as the Compliance Officer.

Under no circumstances may an Employee discuss the suspicious activity, or the fact that it has been referred to the Compliance Officer, with the Client concerned.

The Compliance Officer shall determine whether to report to appropriate law enforcement officials any suspicious activity of which he becomes aware.

The Firm shall require its Clients to acknowledge that the Firm has no responsibility if it reports any suspicious activity, whether from an Employee or from Intermediaries upon whom the Firm relies for Client Identification Procedures.

If and when regulations are adopted concerning reporting of suspicious activities, the Firm will amend this Compliance Manual to comply with those regulations.

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Definitions

• A Close Associate of a Senior Foreign Political Figure is a person who is widely and publicly known internationally to maintain an unusually close relationship with the Senior Foreign Political Figure, and includes a person who is in a position to conduct substantial domestic and international financial transactions on behalf of the Senior Foreign Political Figure.

• A FATF-Compliant Jurisdiction is a jurisdiction that (i) is a member in good standing of FATF and (ii) has undergone two rounds of FATF mutual evaluations.

• Foreign Bank means an organization that (i) is organization under the laws of a foreign country (ii) engages in the business of banking (iii) is recognized as a bank by the bank supervisory or monetary authority of the country of its organization or principal banking operations (iv) receives deposits to a substantial extent in the regular course of its business.

• Foreign Shell Bank means a Foreign Bank without a Physical Presence in any country, but does not include a Regulated Affiliate. Regulated Affiliate means a Foreign Shell Bank that: (i) is an affiliate of a depository institution, credit union, or Foreign Bank that maintains a Physical Presence in the United States or a foreign country, as applicable and (ii) is subject to supervision by a banking authority in the country regulating such affiliated depository institution, credit union, or Foreign Bank.

• The Immediate Family of a Senior Foreign Political Figure typically includes the political figure’s parents, siblings, spouse, children and in-laws.

• Non-Cooperative Jurisdiction means any foreign country that has been designated as non-cooperative with international anti-money laundering principles or procedures by an intergovernmental group or organization, such as the Financial Action Task Force on Money Laundering (“FATF”), of which the United States is a member and with which designation the United States representative to the group or organization continues to concur.

• Physical Presence means a place of business that is maintained by a Foreign Bank and is located at a fixed address, other than solely a post office box or an electronic address, in a country in which the Foreign Bank is authorized to conduct banking activities, at which location the Foreign Bank: (i) employs one or more individuals on a full-time basis (ii) maintains operating records related to its banking activities and (iii) is subject to inspection by the banking authority that licensed the Foreign Bank to conduct banking activities.

• Regulated Affiliate means a Foreign Shell Bank that: (i) is an affiliate of a depository institution, credit union, or Foreign Bank that maintains a Physical Presence in the United States or a foreign country, as applicable and (ii) is subject to supervision by a banking authority in the country regulating such affiliated depository institution, credit union, or Foreign Bank.

• Senior Foreign Political Figure means a senior official in the executive, legislative, administrative, military or judicial branches of a foreign government (whether elected or not), a senior official of a major foreign political party, or a senior executive of a foreign government owned corporation. In addition, a Senior Foreign Political Figure includes any corporation, business or other entity that has been formed by, or for the benefit of, a Senior Foreign Political Figure.

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List of Members of the Financial Action Task Force on Money Laundering (“FATF”)
 

1. Argentina
2. Australia
3. Austria
4. Belgium
5. Brazil
6. Canada
7. Denmark
8. European Commission
9. Finland
10. France
11. Germany
12. Greece
13. Gulf Co-operation Council
14. Hong Kong, China
15. Iceland
16. Ireland
17. Italy
18. Japan
19. Luxembourg
20. Mexico
21. Kingdom of the Netherlands
22. New Zealand
23. Norway
24, Portugal
25. Singapore
26. Spain
27. Sweden
28. Switzerland
29. Turkey
30. United Kingdom
31. United States

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