ANTI-MONEY LAUNDERING POLICY
On October 26, 2001, President George W. Bush signed into law the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (“USA PATRIOT ACT”). Prior to the passage of the USA PATRIOT Act, regulations applying the anti-money laundering provisions of the Bank Secrecy Act (“BSA”) were issued only for banks and certain other institutions that offer bank-like services or that regularly deal in cash. The USA PATRIOT Act required the extension of anti-money laundering requirements to financial institutions, such as registered and unregistered investment companies that had not previously been subjected to BSA regulations. Advisory firms that manage investment companies which are specifically covered by the USA PATRIOT Act must make sure that such registered investment companies create compliance programs and verify a shareholder’s identity.
In April 2003, the Department of the Treasury adopted new rules that would require SEC registered investment advisers and certain unregistered advisers to adopt an anti-money laundering program; the proposed rule exempts funds with liquidity restrictions. In addition, The CFTC through the NFA requires member firms to adopt written anti-money laundering programs to govern the firm’s procedures regarding matters including investor identification, high risk accounts and suspicious activity.
Three Zero Three’s Program
Three Zero Three Capital Partners, LLC (“Three Zero Three”) seeks to prevent the misuse of the funds it manages, as well as preventing the use of its personnel and facilities for the purpose of money laundering, terrorist financing or any other illegal activity. Three Zero Three has adopted procedures and controls with the objective of detecting and deterring the occurrence of money laundering, terrorist financing or other illegal activity and to insure that Three Zero Three’s practices are observed, implemented and properly amended or updated.
New Investors: Prior to accepting a subscription to a fund, Three Zero Three will verify, to the extent reasonable and practicable, the identity of all prospective investors, including the owners and beneficiaries of non-individual accounts.
Prohibited Clients: Three Zero Three as a matter of policy will not be a party to any transaction and will not facilitate any transaction, open accounts, accept funds or securities from, or on behalf of, any person or entity whose name appears on the List of Specially Designated Nationals and Blocked Persons maintained by the U.S. Office of Foreign Assets Control, from any Foreign shell bank or any other prohibited persons or entities as may be mandated by applicable law or regulation.
Annual Training and Review: The Chief Compliance Officer of Three Zero Three will conduct annual employee training programs for appropriate personnel regarding anti-money laundering regulations and the employees’ obligations under such regulations. AML Training programs will review applicable laws and regulations and their relation to Three Zero Three’s business and investment management activities.
Anti-Money Laundering Officer: The Chief Compliance Officer will act as AML Officer. It will be the AML Officer’s responsibility to assure that Three Zero Three’s anti-money laundering polices and procedures are being followed. As such, the AML Officer will be empowered by Three Zero Three with full responsibility and authority to develop and enforce appropriate anti-money laundering policies and procedures, including but not limited to reporting suspicious activity to the appropriate government officials when required. Further, it will be the AML Officer’s responsibility to update and keep current such anti-money laundering polices policies and procedures. A written assessment of Three Zero Three’s anti-money laundering polices policies should be generated, reviewed by the AML Officer and appropriate records maintained.