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ANTI-MONEY LAUNDERING

As part of the Company’s responsibility for the prevention of money laundering, the Company and the Manager will require a detailed verification of an investor’s identity and the source of the payment from any person or business delivering completed Subscription Documents to the Company.
 
In order to comply with proposed regulations aimed at the prevention of money laundering in the United States, the Company is required to verify the identity of all prospective investors and the source of their funds, to the extent required under the USA PATRIOT Act, and to determine if such investors are Prohibited Investors (as defined in the Company’s Subscription Documents) identified on the various lists maintained by the U.S Government.
 
If the Company determines that any investor is a Prohibited Investor, the Company may, among other things, freeze that investor’s assets in the Company and notify appropriate legal authorities.
 
The Company and the Manager reserve the right to request documentation as they deem necessary to verify the identity of a prospective investor and to verify the source of the relevant subscription amounts.
 
The amount of detail required will depend on the circumstances of each application for subscription.
 
Although cash deposits are never accepted into our accounts, the securities industry is unique and can be used to launder funds obtained elsewhere, and to generate illicit funds within the industry itself through fraudulent activities.
 
Examples of types of fraudulent activities include insider trading, market manipulation, ponzi schemes, cybercrime and other investment-related fraudulent activity.
 
Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations.
 
In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment.
 
Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds.
 
Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex. Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable BSA regulations and FINRA rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.
 
A standard process of verification carried by the Company requests any individual to: provide the Company with a copy of the driver’s license or passport proof of address, such as a utility bill or bank statement issued no more than 90 days prior to the date of the Subscription’s Agreement signature proof that the bank account used to send the investment to the Company belongs to the same individual provide the Company with a form stating the bank account that should receive withdrawals, such bank account must be registered under the same name of the individual investing on the Company.
 
For corporate subscribers, the Company may require the production of copies of their certificates of incorporation or other formation documents (and an changes of name) and information concerning their principals and/or beneficial owners.
 
Failure to provide the necessary evidence may result in subscription applications being rejected or in delays in the processing of withdrawals.
In addition to the information we must collect under FINRA Rules 2090 (Know Your Customer) and 2111 (Suitability) and the 4510 Series (Books and Records Requirements), and Securities Exchange Act of 1934 (Exchange Act) Rules 17a-3(a)(9) (Beneficial Ownership regarding Cash and Margin Accounts), 17a-3(a)(17) (Customer Accounts) and Regulation Best Interest, we have established, documented and maintained a written Customer Identification Program (CIP).
 
We will collect certain minimum customer identification information from each customer who opens an account; utilize risk-based measures to verify the identity of each customer who opens an account; record customer identification information and the verification methods and results; provide the required adequate CIP notice to customers that we will seek identification information to verify their identities; and compare customer identification information with government-provided lists of suspected terrorists, once such lists have been issued by the government.
 
Pending the provision of satisfactory evidence as to identity, the evidence of title in respect of the Interests may be retained at the absolute discretion of the Manager.
 
If within a reasonable period of time following a request for verification of identity, the Manager has not received evidence as requested aforesaid, the Manager and the Company may, in their absolute discretion, refuse to allot the Interests applied for, in which even subscription moneys will be returned without interest to the account from which such moneys were originally debited.
 
The Company, the Manager, and the Investment Manager and any agent of the Company, the Manager and the Investment Manager will be held harmless and will be fully indemnified by a potential subscriber against any loss arising because of a failure to process a subscription or withdrawal request if such information requested by any of them or the Manager has not been provided by the applicant.
 
If the Company, the Manager, or the Investment Manager has a suspicion that a payment to the Company (by way of subscription or otherwise) or a payment from the Company (by way of withdrawal or otherwise) contains the proceeds of criminal conduct, the Company, the Manager or the Investment manager may report such suspicion to the appropriate authorities.
 
Neither the Company, the Manager, the Investment Manager, nor any agent of the Company, the Manager or the Investment Manager will incur any liability for adhering to the Company’s responsibilities under its anti-money laundering program and will be indemnified by the Subscriber for any losses which the Company, the Manager, the Investment Manager or their respective principals, employees or agents may incur for doing so.
 
The Manager and the Company reserve the right to request such information as is necessary to verify the identity of a prospective investor.
 
In the event of delay or failure by a prospective investor to produce any information required for verification purposes, the Manager may refuse to accept the prospective investor and the subscription monies relating to it or may refuse to process a withdrawal request until proper information has been provided.
 
To avoid assisting terrorists and certain other persons designated by the U.S. government as wrong-doers, the Fund takes steps to comply with applicable anti-money laundering laws. Those steps include (among others) obtaining certain representations and warranties from Investors, and taking reasonable steps to verify the identity of Investors.
 
Without limiting the foregoing, Investor agrees to provide any information and execute and deliver such documents as deemed necessary by the Investment Manager in their sole discretion, to verify the accuracy of Investor’s representations, warranties, and covenants herein or to comply with any law or regulation to which the Fund.
The Investment Manager or the Investment Manager may be subject, including but not limited to the Investment Manager’s anti-money laundering and anti-terrorist financing program and related responsibilities.
A. Investor understands that the Fund prohibits the investment of funds by any persons or entities that are acting, directly or indirectly, (i) in contravention of any U.S. or international laws and regulations, including anti-money laundering regulations or conventions, (ii) on behalf of terrorists or terrorist organizations, including those persons or entities that are included on the List of Specially Designated Nationals and Blocked Persons maintained by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”), as the list may be amended from time to time,(iii) for a Senior Foreign Political Figure, any Immediate Family member of a Senior Foreign Political Figure or any Close Associate of a Senior Foreign Political Figure, unless the Investment Manager, after being specifically notified by Investor in writing that it is such a person, conducts further due diligence, and determines that such investment shall be permitted, or (iv) for a Foreign Shell Bank (such persons or entities in (i) – (iv) being collectively referred to below as “Prohibited Investors”). 
B. Investor understands that, if any of the foregoing representations, warranties or covenants ceases to be true or if the Fund no longer reasonably believes that it has satisfactory evidence as to their truth, notwithstanding any other agreement to the contrary, the Fund may, in accordance with applicable regulations, be obligated to freeze Investor’s investment, either by prohibiting additional investments, declining or suspending any withdrawal requests and/or segregating the assets constituting the investment, or Investor’s investment may immediately be involuntarily withdrawn from the Fund, and the Fund may also be required to report such action and to disclose Investor’s identity to OFAC or other authority. If the Fund is required to take any of the foregoing actions, Investor agrees that Investor shall have no claim against the Fund or the Investment Manager or their respective affiliates, directors, members, partners, shareholders, officers, employees and agents for any damages as a result of any of the aforementioned actions, and Investor further agrees that it shall indemnify and hold harmless all of such persons from any such claim that may be asserted against them by any person.
C. Investor represents, warrants and agrees that: (i) Investor is not a Prohibited Investor, nor is any person or entity controlling, controlled by or under common control with Investor a Prohibited Investor, and (ii) to the extent Investor has any Beneficial Owners, (a) Investor has carried out thorough due diligence to establish the identities of such Beneficial Owners, (b) based on such due diligence, Investor reasonably believes that no such Beneficial Owner is a Prohibited Investor, (c) Investor holds the evidence of such identities and status and will maintain all such evidence for at least five years from the date of Investor’s complete withdrawal from the Fund, and (d) Investor will make available such information and evidence, and any related additional information that the Fund may request, in accordance with applicable regulations.
D. Investor agrees that all subscription payments transferred to the Fund on behalf of Investor shall originate directly from a bank or brokerage account in the name of Investor. Investor agrees further that any withdrawal proceeds paid to Investor will be paid to the account from which Investor’s investment in the Fund was originally received, unless the Investment Manager, in its sole discretion, agrees otherwise with Investor.
Beneficial Owner is any individual or entity that will have a beneficial ownership interest in Investor’s Interest in the Fund, including but not limited to: (i) shareholders of a corporation; (ii) partners of a partnership; (iii) members of a limited liability company; (iv) investors in a fund- of-funds; (v) the grantor of a revocable or grantor trust; (vi) the beneficiaries of an irrevocable trust; (vii) the individual who established an IRA; (viii) the participant in a self-directed pension plan; (ix) the sponsor of any other pension plan; and (x) any person being represented by Investor in an agent, representative, intermediary, nominee or similar capacity. If the Beneficial Owner is itself an entity, the information and representations set forth herein must also be given with respect to its individual beneficial owners.
 
If Investor is a publicly traded company, it need not conduct due diligence as to its beneficial owners.
 
Close Associate of a Senior Foreign Political Figure is a person who is widely and publicly known internationally to maintain an unusually close relationship with the Senior Foreign Political Figure, and includes a person who is in a position to conduct substantial domestic and international financial transactions on behalf of the Senior Foreign Political Figure.
 
FATF-Compliant Jurisdiction is a jurisdiction that (1) is a member in good standing of FATF and (2) has undergone two rounds of FATF mutual evaluations. FATF means the Financial Action Task Force on Money Laundering.
 
Foreign Bank means an organization that (1) is organized under the laws of a non-U.S. country (2) engages in the business of banking, (3) is recognized as a bank by the bank supervisory or monetary authority of the country of its organization or principal banking operations, (4) receives deposits to a substantial extent in the regular course of its business, and (5) has the power to accept demand deposits, but does not include the U.S. branches or agencies of a non- U.S. bank.
 
Foreign Shell Bank means a Foreign Bank without a Physical Presence in any country, but does not include a Regulated Affiliate. Immediate Family of a Senior Foreign Political Figure typically includes such person’s parents, siblings, spouse, children and in-laws. Non-Cooperative Jurisdiction means any non-U.S. country that has been designated as non- cooperative with international anti-money laundering principles or procedures by an intergovernmental group or organization, such as the FATF, of which the United States is a member and with which designation the United States representative to the group or organization continues to concur. For a current list of Non-Cooperative Countries and Territories, refer to the Financial Action Task Force website (see link above at definition of “FATF-Compliant Jurisdiction”).
 
Physical Presence means a place of business that is maintained by a Foreign Bank and is located at a fixed address, other than solely a post office box or an electronic address, in a country in which the Foreign Bank is authorized to conduct banking activities, at which location the Foreign Bank (1) employs one or more individuals on a full-time basis, (2) maintains operating records related to its banking activities, and (3) is subject to inspection by the banking authority that licensed the Foreign Bank to conduct banking activities.
Regulated Affiliate means a Foreign Shell Bank that (1) is an affiliate of a depository institution, credit union or Foreign Bank that maintains a Physical Presence in the United States or a non- U.S. country, as applicable, and (2) is subject to supervision by a banking authority in the country regulating such affiliated depository institution, credit union or Foreign Bank.
 
Prohibited Investor means: (1) a person or entity whose name appears on one or more of the various lists issued and maintained by the U.S. Office of Foreign Assets Control (“OFAC”), including the List of Specially Designated Nationals and Blocked Persons, the Specially Designated Terrorists List and the Specially Designated Narcotics Traffickers List; (2) a Foreign Shell Bank; or (3) a person or entity who is a citizen or resident of, or which is located in, or whose subscription funds are transferred from or through, a Foreign Bank in a Non-Cooperative Jurisdiction or Sanctioned Regime. Sanctioned Regimes means targeted foreign countries, terrorism sponsoring organizations and international narcotics traffickers in respect of which OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals. Senior Foreign Political Figure means a senior official in the executive, legislative, administrative, military or judicial branch of a foreign government (whether elected or not), a senior official of a major foreign political party, or a senior executive of a foreign government- owned corporation.
 
In addition, a Senior Foreign Political Figure includes any corporation, business or other entity that has been formed by, or for the benefit of, a Senior Foreign Political Figure. USA Patriot Act means the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001 (Pub. L. No. 107- 56).
 

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Arbtrust LLC is a Company based in Florida. Any prospective investors that wish to subscribe units of the Abrtrust LLC operations should contact us through the contact form. This website is not an offer to buy or sell, nor is it a solicitation of an offer to buy or sell, the Units or any other security or to participate in any advisory services or trading strategy. Any offering or solicitation will be made only to certain qualified investors who are “accredited investors” as defined under Regulation D of the Securities Act, and any investments by U.S. persons will only be permitted to potential investors who demonstrate that status. Investors in the Shares must have the financial ability, sophistication, experience, and willingness to bear the risks of such investment.

Arbtrust Venture LLC (the “fund”) operates pursuant to SEC rule 506(b) of regulation D. The membership interests of the fund have not been registered under the securities act of 1933 (the “securities act”), or the securities laws of any state.  Abrtrust performs arbitrage in the negotiation of digital assets, the simultaneous buy and sell of a specific asset taking advantage of the fluctuation of the price of the same asset; and also invests in international private companies.

Historical returns, economic, market or other performance it is not an indication of future results. Potential investors must have the financial ability, sophistication, experience, and willingness to bear the risks of an investment.

Any potential investments made in the company involve risk. Potential investors should carefully consider the long term nature of an investment in the Units prior to making an investment decision.  Units of the company are not insured by the FDIC.

TO REGISTER FOR ACCESS TO  INVESTMENT MATERIALS.THIS CONFIDENTIAL DOCUMENT DOES NOT CONSTITUTE AN OFFER TO SELL OR ADVISE, IS FOR INFORMATIONAL PURPOSES ONLY WITH NO WARRANTY MADE EXPRESS OR IMPLIED TO ITS ACCURACY. ACCREDITED INVESTORS ONLY.