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AML (Anti-Money Laundering) Policy

Broker Junction, Series L.L.C. (hereafter, BJS), recognizes the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (“Act”), which imposes important new obligations on all financial entities for the detection, deterrence and reporting of money laundering activities. The Act, defines money laundering as any financial transaction using income derived from criminal activity including, but not limited to, fraud, illegal gambling, terrorism and drug trafficking. BJS has established the following policies to warrant compliance with all laws and regulations regarding money laundering.

BJS identifies and documents each prospective client’s source of income and assets, investment objectives and nature of business prior to accepting and opening any new account. Accounts for persons or entities from countries that do not cooperate with the Financial Action Task Force (FATF) guidelines on money laundering shall be subject to a heightened level of scrutiny. Accounts in the name of, or related to, any person or entity on the Office of Foreign Asset Control (OFAC) Specially Designated Nationals and Blocked Person list shall not be permitted.

BJS inspects account activities for evidence of suspicious transactions that may be indicative of money laundering activities, on an ongoing basis. Such inspections may particularly include: 1) money flows into and out of accounts, 2) the origin and destination of wire transfers, 3) non-economic transactions, and 4) other activity outside the normal course of business.

Every officer, employee and associated person (“AP”) of BJS shall be responsible for assisting the firm’s efforts to uncover and report any activity that might constitute, indicate or raise suspicions of money laundering. To this end, BJS shall provide continuing education and training of all such persons.

Should any officer, employee or AP of BJS have any knowledge, suspicions or information regarding potential money laundering activities, that individual shall immediately notify BJS’s Compliance Department. BJS’s Compliance Officer shall document the reported activity, investigate fully, and, if warranted, report such activity to the senior management of BJS.

BJS shall accord to all trade and economic sanctions imposed by OFAC against targeted foreign countries and shall cooperate fully with government agencies, self-regulatory organizations and law enforcement officials. As provided by the Act, BJS may supply information about former, current or prospective clients to such bodies.

Any officer, employee or AP who fails to comply with BJS’s policies and procedures on money laundering may be subject to disciplinary action, including termination of employment. In addition, such failure may expose the individual to civil and criminal penalties under the Act.