AML & CTF Policy

The purpose of this AML & CTF Policy is to ensure that Axis Capital Management, LLC ("Axis Capital") and its personnel comply with all applicable U.S. federal and state laws and regulations related to the prevention of money laundering, terrorist financing, and financial crime.

This Policy is intended to raise awareness among employees regarding potential financial crime risks and to ensure understanding of internal procedures designed to prevent Axis Capital from being used for illicit purposes.

Misuse of the Firm for financial crime can result in severe reputational, legal, and regulatory consequences. This Policy supports Axis Capital’s Code of Conduct, which emphasizes the importance of compliance with U.S. laws and regulations.

This Policy is approved by the Board of Directors of Axis Capital and is reviewed at least annually in connection with the Firm’s Enterprise Risk Assessment.

This Policy must be read in conjunction with:

A. Axis Capital’s Customer Identification Program (CIP), Know‑Your‑Customer (KYC), and Due Diligence procedures
B. Risk‑Based Onboarding and Enhanced Due Diligence procedures (including screening for PEPs, sanctions, and adverse media)
C. Compliance Monitoring and Testing policies

As a U.S.-registered investment adviser under the Investment Advisers Act of 1940, Axis Capital is subject to AML requirements under the Bank Secrecy Act, USA PATRIOT Act, and related regulations. Axis Capital has implemented policies and controls designed to detect, prevent, and report suspicious activity.

Money laundering involves disguising the origins of criminal proceeds to make them appear legitimate. Axis Capital employees must understand and comply with relevant U.S. regulatory obligations.

Money laundering typically involves three stages, though not all transactions follow each stage:

Placement: Introducing illicit funds into the financial system.
Layering: Conducting transactions to obscure the audit trail.
Integration: Reintroducing funds into the economy as seemingly legitimate.

Axis Capital personnel must monitor for indicators of suspicious activity, including:

• Large or frequent deposits inconsistent with a client’s profile
• Rapid withdrawals with minimal trading activity
• Funding from unknown or third-party sources
• Unusual trading patterns inconsistent with stated objectives
• Attempts to evade sanctions, PEP, or adverse media screening

All suspicions must be reported promptly to the Chief Compliance Officer (CCO), who will investigate and file Suspicious Activity Reports (SARs) with FinCEN as needed.

Axis Capital employs a risk-based CDD policy for client onboarding, including verification of identity, source of funds, investment objectives, and screening against sanctions and PEP lists. High-risk clients are subject to Enhanced Due Diligence (EDD).

All employees receive initial AML/CTF training, with annual refreshers. Training includes BSA/AML requirements, SAR obligations, and internal reporting procedures. Additional training is provided as regulations evolve.

Axis Capital retains client identity and transaction records for at least five years following account termination or last transaction, in compliance with SEC and BSA rules. Training logs are also maintained.

Axis Capital monitors for transactions that may involve terrorist financing. Any suspicious activity must be reported to the CCO, who will file SARs with FinCEN if warranted.

Fraud, defined as intentional misrepresentation or deception, is prohibited. Safeguards include:

• Code of Conduct requiring honesty and integrity
• Client authentication and multi-factor verification
• Controls over payment instructions and execution
• Fraud awareness training aligned with AML efforts

Axis Capital strictly prohibits bribery under U.S. laws, including the Foreign Corrupt Practices Act (FCPA). Employees must report gifts or hospitality that raise conflicts of interest. A whistleblower channel is available.

Axis Capital prohibits insider trading, market manipulation, and misuse of material non‑public information. Any suspicious activity must be reported to the CCO.

7.1 Board of Directors: Approve and review AML/CTF Policy and receive annual risk assessments.
7.2 Chief Compliance Officer (CCO): Adminsters the Policy, oversees training, investigates suspicious activity, and files SARs.
7.3 Ongoing Monitoring: The CCO oversees daily and periodic reviews of client accounts and transactions. Third-party deposits are prohibited; all client funding must originate from verified sources. The Firm retains discretion to refuse transactions linked to financial crime.

Employees and associated persons must sign a declaration confirming that they have read, understood, and will comply with Axis Capital Management’s AML, CTF, and financial crime prevention policies.