Anti Money Laundering (AML) Policy

Our AML policy is designed to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of criminal activities.

The AML 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
• Communicate with employees of the firm to ensure compliance with this policy.

Client Identification and Verification

Prior to establishing a new client relationship, we must 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, or SSN.