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Anti-Money Laundering (AML) Policy

It is the policy of the firm to prohibit and actively prevent money laundering and any activity that facilitates money
laundering or the funding of terrorist or criminal activities.

Anti-Money Laundering Program

The CCO shall:
➢ Monitor the firm’s compliance with this policy;
➢ Monitor changes in applicable laws and regulations relating to money laundering and implement further
controls as may be required by such changes in laws and regulations;
➢ Ensure the firm keeps the records required by this policy;
➢ Ensure Suspicious Activity Reports (SAR-SFs) are filed when required by applicable law and regulations;
and
➢ Train employees of the firm to ensure compliance with this policy.

Anti-Money Laundering Program Compliance Officer Appointment
The person herein named “Anti-Money Laundering Program Compliance Officer” has full responsibility for the
firm’s AML program. This person is qualified by experience, knowledge and training. The duties of the AML
Compliance Officer will include monitoring the firm’s compliance with AML obligations and overseeing
communication and training for employees. The AML Compliance Officer will also ensure that proper AML records
are kept as required by law. When warranted, the AML Compliance Officer will ensure Suspicious Activity Reports
(SAR-SFs) are filed.

AML Compliance Officer Date Responsibility Assumed
John Riley 03/12/2012

Supervisor Date Responsibility Assumed
John Riley 03/12/2012

Client Identification and Verification
Prior to establishing a new client relationship, the firm will obtain and review the following information to verify
the identity of the client:
➢ The client’s legal name;
➢ The client’s date of birth (if the client is an individual);
➢ The client’s physical address (not a P.O. Box or email address);
➢ The client’s telephone number;
➢ The client’s government identification number (e.g., tax identification number, social security number, or
passport number with country of issuance);
➢ A short description of the client’s primary business, if any; and
➢ A short description of the client’s primary source of funds (e.g., business listed above, inheritance,
pension).

Clients Who Refuse to Provide Information
If a potential or existing client either refuses to provide the information described above or appears to have
intentionally provided misleading information, CIS will not open a new account and, after considering the risks
involved, consider closing any existing account. In either case, CIS’s CCO will be notified so that CIS can determine
whether it should file a Form SAR-SF.

Verifying Information
CIS will ensure that it has a reasonable belief that it knows the true identity of its clients by using risk-based
procedures to verify and document the accuracy of the information it receives about its clients. In verifying client
identity, CIS will analyze any logical inconsistencies in the information it obtains.