UPDATED AS OF January 31, 2022

1. Firm Policy

It is the policy of the Stoneguard Willows MDQ Ltd., consisting of several legal entities within several jurisdictions (hereinafter collectively referred to as “the firm” or “the company”) to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the law and implementing regulations within the company’s existing projects.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s checks, or deposited into accounts at financial institutions. At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

Although cash is rarely deposited into securities accounts, the securities industry is unique in that it can be used to launder funds obtained elsewhere and to generate illicit funds within the industry itself through fraudulent activities. Examples of types of fraudulent activities include insider trading, market manipulation, Ponzi schemes, cybercrime, and other investment-related fraudulent activity.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership, and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.

Our AML policies, procedures, and internal controls are designed to ensure compliance with all applicable regulations and authorized body rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures, and internal controls are in place to account for both changes in regulations and changes in our business.

2. AML Compliance Person Designation and Duties

The firm has designated a compliance officer as its Anti-Money Laundering Program Compliance Person (AML Compliance Person), with full responsibility for the firm’s AML program. A compliance officer shall be appointed by the company’s director or board of directors. The compliance officer has a working knowledge of the implementing regulations and is qualified by experience, knowledge, and training. The duties of the AML Compliance Person will include monitoring the firm’s compliance with AML obligations, overseeing communication and training for employees, and any other duties decided by the director. The AML Compliance Person will also ensure that the firm keeps and maintains all of the required AML records and will ensure that Suspicious Activity Reports (SARs) are filed with the authorized body when appropriate. The AML Compliance Person is vested with full responsibility and authority to enforce the firm’s AML program.

The firm will provide the authorized body with contact information for the AML Compliance Person, including: (1) name; (2) title; (3) mailing address; (4) email address; (5) telephone number; and (6) facsimile (if any). The firm will promptly notify the authorized body of any change in this information and will review, and if necessary update, this information within 17 business days after the end of each calendar year. The annual review of authorized body information will be conducted by the compliance officer and will be completed with all necessary updates being provided no later than 17 business days following the end of each calendar year. In addition, if there is any change to the information, the compliance officer will update the information promptly, but in any event not later than 30 days following the change.

3. Giving AML Information to the authorized body and Financial Institutions

Authorized body Requests

We will respond to an authorized body request concerning accounts and transactions by immediately searching our records to determine whether we maintain or have maintained any account for, or have engaged in any transaction with, each individual, entity, or organization named in the Request. We understand that we have 14 days (unless otherwise specified by the respective authorized body) from the transmission date of the request to respond to a request.

If the compliance officer searches our records and does not find a matching account or transaction, then the compliance officer might not reply to the Request. We will maintain documentation that we have performed the required search by printing a search self-verification document confirming that your firm has searched the subject

information against your records OR maintaining a log showing the date of the request, the number of accounts searched, the name of the individual conducting the search, and a notation of whether or not a match was found.

We will not disclose the fact that the authorized body has requested or obtained information from us, except to the extent necessary to comply with the information request. The compliance officer will review, maintain and implement procedures to protect the security and confidentiality of requests from the authorized body similar to those procedures established to satisfy the requirements of the law with regard to the protection of customers’ nonpublic information.

We will direct any questions we have about the Request to the requesting law enforcement agency as designated in the request.

Unless otherwise stated in the Request, we will not be required to treat the information request as continuing in nature, and we will not be required to treat the periodic Requests as a government-provided list of suspected terrorists for purposes of the customer identification and verification requirements.

We will employ strict procedures both to ensure that only relevant information is shared and to protect the security and confidentiality of this information, for the authorized body, by segregating it from the firm’s other books and records.


We also will employ procedures to ensure that any information received from another financial institution shall not be used for any purpose other than:

  • identifying and, where appropriate, reporting on money laundering or terrorist activities;

  • determining whether to establish or maintain an account or to engage in a transaction; or

  • assisting the financial institution in complying with performing such activities.​

4. Checking the Office of Foreign Assets Control Listings

Before opening an account, and on an ongoing basis, the compliance officer will check to ensure that a customer does not appear on the SDN list or is not engaging in transactions that are prohibited by the economic sanctions and embargoes administered and enforced by the authorized body. Because the list and listings of economic sanctions and embargoes are updated frequently, we will consult them on a regular basis and subscribe to receive any available updates when they occur. With respect to the SDN list, we may also access that list through various software programs to ensure speed and accuracy. The compliance officer will also review existing accounts against the SDN list and listings of current sanctions and embargoes when they are updated and the compliance officer will document the review.

If we determine that a customer is on the SDN list or is engaging in transactions that are prohibited by the economic sanctions and embargoes administered and enforced by an authorized body, we will reject the transaction and/or block the customer’s assets and file blocked assets and/or rejected transaction form with the authorized body within 10 days.

5. AML Recordkeeping

a. Responsibility for Required AML Records and SAR Filing

Our AML Compliance Person and his or her designee will be responsible for ensuring that AML records (including registers of customers who are PEPs and CEPs and a record of all filed SARs) are maintained properly and that SARs are filed as required.

In addition, as part of our AML program, our firm will create and maintain SARs and relevant documentation on customer identity and verification and funds transmittals. We will maintain SARs and their accompanying documentation for at least five years. We will keep other documents according to existing regulations and other recordkeeping requirements, including certain rules that require retention periods.


b. SAR Maintenance and Confidentiality

We will hold SARs and any supporting documentation confidential. We will not inform anyone outside of appropriate law enforcement or regulatory agency about a SAR.

We will refuse any subpoena requests for SARs or for information that would disclose that a SAR has been prepared or filed and immediately notify the authorized body of any such subpoena requests that we receive. We will segregate SAR filings and copies of supporting documentation from other firm books and records to avoid disclosing SAR filings. Our AML Compliance Person will handle all subpoenas or other requests for SARs. We may share information with another financial institution about suspicious transactions in order to determine whether we will jointly file a SAR. In cases in which we file a joint SAR for a transaction that has been handled both by us and another financial institution, both financial institutions will maintain a copy of the filed SAR.

6. Applicable Laws

In order to be compliant with the AML regulations for every of the existing Stoneguard Willows MDQ Ltd. projects, we apply both national (of places where our certain companies are registered or operate, depending on the project) and international regulations

We monitor the changes of the applicable laws on the annual basis and, if necessary, amend our policies and procedures accordingly.​

7. Firm Relationships

We will work closely with the authorized body to detect money laundering. We will exchange information, records, data, and exception reports as necessary to comply with AML laws. Our firm will have filed (and kept updated) the necessary annual certifications for such information. As a general matter, we will obtain and use the following exception reports offered by our authorized body in order to monitor customer activity and we will provide the authorized body with proper customer identification and due diligence information as required to successfully monitor customer transactions. We have discussed how each firm will apportion customer and transaction functions and how we will share information and set forth our understanding in a written document. We understand that the apportionment of functions will not relieve either of us from our independent obligation to comply with AML laws, except as specifically allowed under the authorized body and its implementing regulations.

As noted above, in the BVI the authorized body is charged with overseeing the investigation of money laundering, and the body with which SARs are to be filed is the BVI Financial Investigation Agency. SARs to be filed with the BVI FIA are to be in the approved form for an External SAR found on the website of the FIA.


8. Training Programs

We will develop ongoing employee training under the leadership of the AML Compliance Person and senior management. Our training will occur on at least an annual basis. It will be based on our firm’s size, its customer base, and its resources and be updated as necessary to reflect any new developments in the law.

Our training will include, at a minimum: (1) how to identify red flags and signs of money laundering that arise during the course of the employees’ duties; (2) what to do once the risk is identified (including how, when, and to whom to escalate unusual customer activity or other red flags for analysis and, where appropriate, the filing of SARs); (3) what employees’ roles are in the firm’s compliance efforts and how to perform them; (4) the firm’s record retention policy; and (5) the disciplinary consequences (including civil and criminal penalties) for non-compliance with the regulations.

We will develop training in our firm, or contract for it. Delivery of the training may include educational pamphlets, videos, intranet systems, in-person lectures, and explanatory memos. We will maintain records to show the persons trained, the dates of training, and the subject matter of their training.

We will review our operations to see if certain employees, such as those in compliance, margin, and corporate security, require specialized additional training. Our written procedures will be updated to reflect any such changes.

9. Monitoring Employee Conduct and Accounts

We will subject employee accounts to the same AML procedures as customer accounts, under the supervision of the AML Compliance Person. We will also review the AML performance of supervisors, as part of their annual performance review. The AML Compliance Person’s accounts will be reviewed by the director.

10. Confidential Reporting of AML Non-Compliance

Employees will promptly report any potential violations of the firm’s AML compliance program to the AML Compliance Person unless the violations implicate the AML Compliance Person, in which case the employee shall report to the director. Such reports will be confidential, and the employee will suffer no retaliation for making them.


11. Additional Risk Areas

The firm has reviewed all areas of its business to identify potential money laundering risks that may not be covered in the procedures described above.