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Anti-Money Laundering Policy

ANTI-MONEY LAUNDERING SUMMARY POLICY STATEMENT

It is the policy of Outside Investment Advisors to comply with the Patriot Act.

This policy statement is an integral part of Outside Investment Advisor’s Anti-Money Laundering Policy, which includes procedures and personnel responsible for complying with this policy and applicable laws.

Reason for Policy/Purpose
The purpose of this policy is to ensure Outside Investment Advisors compliance with anti-money laundering laws and regulations, to assist law enforcement in combating illegal money laundering, and to minimize the risk of Outside Investment Advisors (OIA) resources being used for improper purposes. Failure to comply with anti-money laundering regulations could result in civil and criminal penalties to OIA and/or individual employees and Directors.

Who Needs to Know This Policy
All OIA Staff, Management and its Directors need to know this policy.

Policy/Procedures
Money laundering is the process of concealing the existence, illegal source, or application of income derived from criminal activity, and the subsequent disguising of the source of that income to make it appear legitimate. OIA is committed in assisting the Financial Intelligence Unit in detecting, preventing and eradicating terrorist financing and terrorist and criminal activity.  OIA will evaluate all financial transactions and take all necessary steps to comply with anti-money laundering laws and regulations, listed in detailed in the OIA Policy and Procedure Manual.

Client Identification Procedures
As part of OIA’s AML policy, the firm has established procedures to ensure that all clients’ identities are verified prior to opening an account. Before opening an account for an individual client, OIA will require satisfactory documentary evidence of a client’s name, address, date of birth, and either but not limited to the following forms of identification:

  • Passport ID and number
  • Driver’s License

For a corporation or other legal entity, OIA will require satisfactory legal evidence of the entity’s name, address and that the beneficiary and operators have been duly authorized to open the account. The AML Compliance Officer will retain records of all documentation that have been relied upon for client/corporation identification.

Prohibited Accounts
OIA will not open accounts or accept funds or securities from, or on behalf of, any person or entity nor accept high-risk clients (with respect to money laundering or terrorist financing) without conducting enhanced, well-documented due diligence regarding such prospective client.

Concerns regarding transactions that are unusually large or that appear suspicious, questions regarding money laundering in general and any violation of this policy should be reported to OIA’s Compliance Officer at support@outsideia.com OIA – Anti-Money Laundering Policy

Training and Review
The AML Compliance Officer will conduct Semi-annual employee training programs for all personnel regarding the AML policy. Such training programs will review applicable laws, regulations and recent trends in money laundering and their relation to OIA’s business. Attendance at these programs is mandatory for all personnel, session and attendance records will be retained for a three-year period.

Website Addresses for the complete AML Policy 
http://www.outsideia.com/AML-Policy

Who Approved This Policy
Board of Directors – Outside Investment Advisors