Alumni Ventures’ AML & KYC Regulatory Requirements

As an investment advisor, Alumni Ventures is required to have anti-money laundering (“AML”) and know your customer (“KYC”) programs

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The U.S. imposes various regulatory requirements on financial institutions and entities participating in the transfers of money as part of their businesses. As an investment advisor, Alumni Ventures is required to have anti-money laundering (“AML”) and know your customer (“KYC”) programs so that we do not facilitate money laundering — and can demonstrate that we have taken appropriate steps in that regard, including confirmation of customer identity.

As part of these efforts, Alumni Ventures has engaged Parallel Markets, who also performs our verifications of each investor’s accredited investor status. For AML, we have Parallel Markets check all of our investors at the time of investment against the various OFAC and other blacklists of individuals with which we should not be doing business. When there is a possible hit, the customer information is reviewed in order to determine that the investor is not the individual on the list, utilizing information provided by the investor. Parallel Markets will run these screens continuously thereafter and alert Alumni Ventures if there is a subsequent potential hit.

Under the KYC program, Parallel Markets checks additional information. Potential investors supply relevant documentation of identity, including for individuals, a formal picture ID such as a driver license or passport. Parallel Markets will use the information provided and prepare a Tax ID form, such as a W-9 or W-8, for the investor to sign. These need to be refreshed periodically with Parallel Markets.

It is important to note that successful completion of the KYC process is required for every new investor. AV will not be able to send any fund distributions to a new investor who has not successfully completed the KYC process, and AV will hold any funds until the investor has done so.

We are pleased to partner with Parallel Markets to perform these important services and meet regulatory requirements. Parallel Markets and your Investor Relations team can help answer any questions about various requirements.

Contact [email protected] for additional information. To see additional risk factors and investment considerations, visit av-funds.com/disclosures.