Anti-Money Laundering (AML) Policy

It is the policy of the firm to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities.

Anti-Money Laundering Program

The CCO shall:

●  Monitor the firm’s compliance with this policy;

●  Monitor changes in applicable laws and regulations relating to money laundering and implement further controls as may be required by such changes in laws and regulations;

●  Ensure the firm keeps the records required by this policy;

●  Ensure Suspicious Activity Reports (SAR-SFs) are filed when required by applicable law and regulations; and

●  Train employees of the firm to ensure compliance with this policy.

Client Identification and Verification

Prior to establishing a new client relationship, the firm will obtain and review the following information to verify the identity of the client:

●  The client’s legal name;

●  The client’s date of birth (if the client is an individual);

●  The client’s physical address (not a P.O. Box or email address);

●  The client’s telephone number;

●  The client’s government identification number (e.g., tax identification number, social security number, or passport number with country of issuance);

●  A short description of the client’s primary business, if any; and

●  A short description of the client’s primary source of funds (e.g., business listed above, inheritance, pension).


Clients Who Refuse to Provide Information
If a potential or existing client either refuses to provide the information described above or appears to have intentionally provided misleading information, Adviser will not open a new account and, after considering the risks involved, consider closing any existing account. In either case, Adviser’s CCO will be notified so that Adviser can determine whether it should file a Form SAR-SF.


Verifying Information

Adviser will ensure that it has a reasonable belief that it knows the true identity of its clients by using risk-based procedures to verify and document the accuracy of the information it receives about its clients. In verifying client identity, Adviser will analyze any logical inconsistencies in the information it obtains.


Adviser will verify its client’s identity through documentary evidence or non-documentary evidence, as necessary. In analyzing the verification information, Adviser will consider whether there is a logical consistency among the identifying information provided, such as the client’s name, street address, zip code, telephone number (if provided), date of birth, and social security number.


If Adviser detects any red flags that indicate possible money laundering or terrorist financing activity, it will, after internal consultation with the firm's CCO, file a SAR-SF in accordance with applicable law and regulation.


Lack of Verification

When Adviser cannot form a reasonable belief that it knows the true identity of a client, it will do the following: (1) not open an account; (2) impose terms under which a client may conduct transactions while it attempts to verify the client’s identity; (3) close an account after attempts to verify client’s identity fail; or (4) file a SAR-SF if required by applicable law and regulation.


Recordkeeping

Adviser will document its verification, including identifying information provided by a client, the methods used and results of verification, and the resolution of any discrepancy in the identifying information. Adviser will keep records containing a description of any document that it relied on to verify a client’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, Adviser will retain documents that describe the methods and the results of any measures it took to verify the identity of a client. Adviser will maintain records of identification information for five years after the account has been closed; it will retain records made about verification of the client's identity for five years after the record is made.


Responsibility for AML Records and SAR Filing

Adviser’s CCO will be responsible for ensuring that AML records are maintained properly and that SARs are filed as required. Adviser will maintain AML records and their accompanying documentation for at least five years. Adviser will keep other documents according to existing Bank Secrecy Act and other record keeping requirements.


Training Programs

The CCO will develop and conduct ongoing employee training. Adviser’s training will occur on at least an annual basis or when material changes occur to the AML policy and procedures.


Adviser will maintain records to show the persons trained, the dates of training, and the subject matter of their training.


Adviser’s training will include, at a minimum: how to identify red flags and signs of money laundering that arise during the course of the employees’ duties; what to do once the risk is identified; what employees' roles are in the firm's compliance efforts and how to perform them; the firm's record retention policy; and the disciplinary consequences (including civil and criminal penalties) for non-compliance with the PATRIOT Act.

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