AML, KYC, and Sanctions Policy
The firm’s framework for customer identification, beneficial-ownership verification, sanctions screening, and suspicious-activity reporting.
1. Purpose
This policy establishes the firm’s program for detecting and preventing money laundering, terrorist financing, sanctions violations, and other financial crime, consistent with the Bank Secrecy Act, the USA PATRIOT Act, and OFAC regulations.
2. Scope
The policy applies to all funds and accounts managed by Alzaro Capital Management, LLC, to all personnel, and to all subscriptions, distributions, and transfers of fund interests.
3. AML Compliance Officer
The Chief Compliance Officer serves as AML Compliance Officer, responsible for the design, oversight, testing, and continuous improvement of the program, with reporting to senior management and the Limited Partner Advisory Committee on AML matters.
4. Customer Identification & Verification
Before accepting any subscription, the firm verifies the identity of the investor and any beneficial owners, collecting identification, address, taxpayer information, and source of funds for natural persons and formation and ownership documentation for legal entities.
5. Enhanced Due Diligence
Enhanced due diligence is applied to higher-risk investors, including politically-exposed persons, investors in high-risk jurisdictions, and complex ownership structures. Enhanced due diligence is documented and retained.
6. Sanctions Screening
Investors, beneficial owners, counterparties, and material vendors are screened against the OFAC Specially Designated Nationals list and other applicable sanctions lists at onboarding, on a periodic basis, and upon list updates. Matches are escalated immediately.
7. Suspicious Activity Reporting
Personnel report potentially suspicious activity to the AML Compliance Officer, who evaluates each report and, where appropriate, files a Suspicious Activity Report with FinCEN. Tipping off the subject of a report is prohibited.
8. Training
All personnel receive AML, KYC, and sanctions training at hire and annually. Training records are retained for at least five years.
9. Recordkeeping
Identification, beneficial-ownership, due-diligence, screening, and reporting records are retained for the periods required by law, in no case less than five years.
10. Independent Testing
The AML program is subject to periodic independent testing to assess its adequacy and effectiveness.
Notice
This document is a summary of the firm’s internal policy as adopted by the approving body identified above. The complete policy as adopted governs in any case of conflict between this summary and the underlying policy document. Limited partners and other authorized parties may request the full policy from the policy owner. This document does not create contractual rights, employment rights, or third-party beneficiary rights, and may be amended at any time by action of the approving body.
Questions about this policy should be directed to [email protected]. Confidential or anonymous reports may also be made through the channels described in the Whistleblower Policy.
Questions about firm governance
Limited partners, regulators, and counterparties with questions about firm governance, policies, or compliance should contact [email protected].