FXSALT Anti Money Laundering ("AML") Policy

INVESTIGATION

Upon notification to the AML Compliance Committee of a match to the OFAC SDN List or possible suspicious activity, an investigation will be commenced to determine if a report should be made to appropriate law enforcement or regulatory agencies. The investigation will include, but not necessarily be limited to, review of all available information, such as payment history, birth dates, and address. If the results of the investigation warrant, a recommendation will be made to the AML Compliance Committee to file a blocked assets and/or a SAR with the appropriate law enforcement or regulatory agency. The AML Compliance Committee is responsible for any notice or filing with law enforcement or regulatory agency.

Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know. Under no circumstances shall any officer, employee or appointed agent disclose or discuss any AML concern, investigation, notice or SAR filing with the person or persons subject of such, or any other person, including members of the officer's, employee's or appointed agent's family.

RECORDKEEPING

The AML Compliance Committee will be responsible to ensure that AML records are maintained properly and that SARs and Blocked Property Reports are filed as required. FXSALT will maintain AML records for at least five years.

TRAINING

FXSALT shall provide general AML training to its officers, employees and appointed producers to ensure awareness of requirements under the FIAMLA. The training will include, at a minimum: how to identify redflags and signs of money laundering; what roles the officers, employees and appointed producers have in the FXSALT compliance efforts and how to perform such duties and responsibilities; what to do once a red flag or suspicious activity is detected; FXSALT record retention policy; and the disciplinary consequences for non‐compliance with the Act and this Policy. In addition, each affected area will provide enhanced training in accordance with the procedures developed in each area for officers and employees reasonably expected to handle money, requests, or processing that may bring them into contact with information designated above. Training will be conducted on an annual basis. The FXSALT AML Compliance Committee will determine the ongoing training requirements and ensure written procedures are updated to reflect any changes required in such training. FXSALT will maintain records to document that training has occurred.

TESTING OF THE POLICY

The testing of the Policy will be conducted by an outside independent third party annually. Any findings will be reported to the AML Compliance Committee, SFG Audit Committee and Senior Management for appropriate action.

ADMINISTRATION

The AML Compliance Committee is responsible for the administration, revision, interpretation, and application of this Policy. The Policy will be reviewed annually and revised as needed