Anti-Money Laundering Policy

1. Introduction

MSSA Global Multi-Asset Strategy ("Company," "we," "our," or "us") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy outlines our approach to preventing the use of our services for money laundering, terrorist financing, or other financial crimes.

Money laundering is the process of concealing the origins of illegally obtained money, typically by means of transfers involving foreign banks or legitimate businesses. Terrorist financing involves the solicitation, collection, or provision of funds with the intention that they may be used to support terrorist acts or organizations.

We are committed to:

• Complying with all applicable AML/CTF laws and regulations
• Implementing robust systems and controls to detect and prevent financial crimes
• Conducting thorough customer due diligence
• Reporting suspicious activities to relevant authorities
• Maintaining comprehensive records
• Providing ongoing training to our staff

2. Regulatory Framework

Our AML/CTF program is designed to comply with applicable laws and regulations, including but not limited to:

2.1 UK Regulations

• Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017
• Proceeds of Crime Act 2002
• Terrorism Act 2000
• Financial Conduct Authority (FCA) Guidelines

2.2 International Standards

• Financial Action Task Force (FATF) Recommendations
• Wolfsberg Group Principles
• Basel Committee on Banking Supervision Guidelines
• EU Anti-Money Laundering Directives (where applicable)

2.3 Regulatory Oversight

As a company registered with the Financial Conduct Authority (FCA) of the United Kingdom under Reference Number 954868, we are subject to regulatory oversight and must comply with all AML/CTF requirements set forth by the FCA.

2.4 Money Laundering Reporting Officer (MLRO)

We have appointed a Money Laundering Reporting Officer (MLRO) who is responsible for:

• Overseeing the implementation of our AML/CTF program
• Receiving and evaluating internal suspicious activity reports
• Filing reports with relevant authorities
• Liaising with regulatory bodies
• Ensuring staff training and awareness

3. Customer Due Diligence (CDD)

We conduct Customer Due Diligence on all clients to verify their identity and assess the risk they may pose. Our CDD process includes:

3.1 Customer Identification

We collect and verify the following information from all customers:

• Full legal name
• Date of birth
• Residential address
• Nationality and country of residence
• Contact information (email, phone number)
• Tax identification number (where applicable)
• Source of funds and wealth
• Purpose of the business relationship

3.2 Verification Requirements

Identity verification is conducted using reliable, independent sources:

• Identity Documents: Government-issued photo ID (passport, national ID card, driver's license)
• Proof of Address: Recent utility bill, bank statement, or government correspondence (dated within 3 months)
• Additional Documents: May be required based on risk assessment

3.3 Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied to higher-risk customers, including:

• Politically Exposed Persons (PEPs) and their associates
• Customers from high-risk jurisdictions
• Customers with complex ownership structures
• Customers with unusual transaction patterns
• High-value customers
• Customers in high-risk industries

EDD measures may include:

• Additional identity verification
• Enhanced source of funds verification
• Senior management approval for account opening
• More frequent account reviews
• Enhanced transaction monitoring

3.4 Simplified Due Diligence

In certain low-risk situations, simplified due diligence may be applied, subject to regulatory requirements and our risk assessment.

4. Know Your Customer (KYC) Procedures

Our KYC procedures are designed to establish and verify the identity of our customers and understand the nature of their activities.

4.1 Required Documents

All customers must provide the following documents:

4.2 Verification Process

Our verification process includes:

1. Document Collection: Customers upload required documents through our secure platform.
2. Document Review: Our compliance team reviews documents for authenticity and completeness.
3. Identity Verification: We use automated and manual checks to verify identity.
4. Database Screening: Customers are screened against sanctions lists, PEP databases, and adverse media.
5. Risk Assessment: Each customer is assigned a risk rating based on various factors.
6. Approval/Rejection: Accounts are approved or rejected based on verification results.

4.3 Ongoing Monitoring

KYC is not a one-time process. We conduct ongoing monitoring including:

• Periodic review of customer information and documents
• Continuous transaction monitoring
• Regular screening against updated sanctions and PEP lists
• Trigger-based reviews when unusual activity is detected
• Annual reviews for high-risk customers

4.4 Document Validity

• Identity documents must be valid (not expired)
• Proof of address must be dated within the last 3 months
• Documents must be clear, legible, and show all four corners
• We may request updated documents periodically

5. Transaction Monitoring

We employ sophisticated transaction monitoring systems to detect potentially suspicious activities.

5.1 Monitoring Systems

Our monitoring systems analyze:

• Deposit and withdrawal patterns
• Trading activity and patterns
• Transaction amounts and frequency
• Geographic locations of transactions
• Payment methods used
• Deviations from expected customer behavior

5.2 Red Flags

We monitor for various red flags, including but not limited to:

• Large or unusual deposits inconsistent with customer profile
• Frequent deposits followed by immediate withdrawals
• Deposits from multiple sources followed by single withdrawals
• Transactions involving high-risk jurisdictions
• Use of multiple payment methods without clear reason
• Reluctance to provide required information
• Inconsistencies in provided information
• Unusual trading patterns (e.g., minimal trading activity)
• Third-party payments

5.3 Automated Alerts

Our systems generate automated alerts for:

• Transactions exceeding certain thresholds
• Patterns matching known money laundering typologies
• Transactions involving sanctioned entities or jurisdictions
• Unusual account activity

5.4 Manual Review

All alerts are reviewed by our compliance team, who may:

• Request additional information from the customer
• Escalate to the MLRO
• File a Suspicious Activity Report (SAR)
• Restrict or close the account

6. Suspicious Activity Reporting

We are committed to reporting suspicious activities to relevant authorities as required by law.

6.1 Internal Reporting

All employees are required to report any suspicious activity to the MLRO immediately. This includes:

• Unusual customer behavior
• Suspicious transactions
• Attempts to avoid reporting thresholds
• Inconsistent or false information
• Any activity that may indicate money laundering or terrorist financing

6.2 External Reporting

The MLRO is responsible for filing Suspicious Activity Reports (SARs) with the National Crime Agency (NCA) of the United Kingdom when there are reasonable grounds to suspect:

• Money laundering
• Terrorist financing
• Other financial crimes

6.3 Tipping Off

6.4 Confidentiality

All suspicious activity reports and related information are treated as strictly confidential and are only shared with authorized personnel and relevant authorities.

7. Record Keeping

We maintain comprehensive records as required by law and best practices.

7.1 Records Maintained

We keep records of:

• Customer identification and verification documents
• Account opening documentation
• Transaction records
• Correspondence with customers
• Internal and external suspicious activity reports
• Risk assessments
• Training records
• Compliance reviews and audits

7.2 Retention Period

Records are retained for the following periods:

• Customer Records: At least 7 years after the end of the business relationship
• Transaction Records: At least 7 years from the date of the transaction
• Suspicious Activity Reports: At least 7 years from the date of filing

7.3 Record Security

All records are stored securely with appropriate access controls and are available for inspection by regulatory authorities upon request.

8. Staff Training

We provide comprehensive AML/CTF training to all employees.

8.1 Training Program

Our training program covers:

• Overview of money laundering and terrorist financing
• Applicable laws and regulations
• Company policies and procedures
• Customer due diligence requirements
• Recognizing suspicious activities
• Reporting procedures
• Consequences of non-compliance

8.2 Training Schedule

• New Employees: Training within the first month of employment
• All Staff: Annual refresher training
• Updates: Additional training when regulations or procedures change
• Specialized Training: Role-specific training for compliance staff

8.3 Training Records

We maintain records of all training provided, including attendance and assessment results.

9. Sanctions Compliance

We are committed to complying with all applicable sanctions regimes.

9.1 Sanctions Screening

We screen all customers and transactions against:

• United Nations Security Council Sanctions Lists
• US Office of Foreign Assets Control (OFAC) Lists
• EU Consolidated Sanctions List
• UK HM Treasury Sanctions List
• Other applicable national and international sanctions lists

9.2 Screening Process

• Initial screening during customer onboarding
• Ongoing screening against updated lists
• Transaction screening for sanctioned entities and jurisdictions
• Manual review of potential matches

9.3 Prohibited Jurisdictions

We do not provide services to residents of certain high-risk or sanctioned jurisdictions, including but not limited to:

• North Korea
• Iran
• Syria
• Cuba
• Crimea region
• Other jurisdictions subject to comprehensive sanctions

9.4 Sanctions Violations

Any potential sanctions match or violation is immediately escalated to the MLRO and, if confirmed, reported to relevant authorities. Accounts associated with sanctioned individuals or entities are frozen and reported.

10. Politically Exposed Persons (PEPs)

We apply enhanced due diligence to Politically Exposed Persons due to the higher risk of corruption and money laundering.

10.1 Definition of PEPs

A PEP is an individual who is or has been entrusted with a prominent public function, including:

• Heads of state or government
• Senior politicians and government officials
• Senior judicial officials
• Senior military officers
• Senior executives of state-owned enterprises
• Important political party officials

This also includes family members and close associates of PEPs.

10.2 PEP Screening

All customers are screened against PEP databases during onboarding and on an ongoing basis.

10.3 Enhanced Due Diligence for PEPs

When a customer is identified as a PEP, we apply:

• Senior management approval for account opening
• Enhanced source of funds and wealth verification
• Enhanced ongoing monitoring
• More frequent account reviews
• Additional documentation requirements

10.4 Risk-Based Approach

Not all PEPs present the same level of risk. We assess each PEP individually based on factors such as:

• The country and position held
• Level of corruption risk in the country
• Whether the PEP is domestic or foreign
• Time since leaving office (for former PEPs)

11. Non-Compliance Consequences

Failure to comply with our AML/CTF policies may result in serious consequences.

11.1 For Customers

Customers who fail to comply with our AML/CTF requirements may face:

• Account restrictions or limitations
• Delayed or refused transactions
• Account suspension or termination
• Reporting to relevant authorities
• Forfeiture of funds (where legally required)

11.2 For Employees

Employees who fail to comply with AML/CTF policies may face:

• Disciplinary action
• Termination of employment
• Personal liability and legal consequences

11.3 For the Company

Non-compliance can result in:

• Regulatory sanctions and fines
• Loss of license
• Reputational damage
• Criminal prosecution of responsible individuals

12. Contact Compliance Team

If you have any questions about our AML/CTF policies or need to report suspicious activity, please contact our Compliance Team: