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Policy

Adviser's policy is to prevent persons from using Adviser and the services it offers to engage in money laundering and other criminal activity.

Background & Description

The USA PATRIOT Act of 2001 requires all "financial institutions" to implement anti-money laundering programs. At present, there has been a proposal to add "investment adviser" to the list of entities that meet the definition of "financial institution", however that proposal has not been implemented. If adopted, this rule would require investment advisers to implement anti-money laundering procedures.

Many investment advisers have voluntarily implemented such procedures. "Money laundering" involves schemes designed to conceal or disguise the source of money obtained illegally, as well as legitimate business activities carried out in a manner that will conceal earnings from the Internal Revenue Service and other taxing authorities in an effort to avoid taxes and potential criminal liability. The SEC advises investment advisers setting up an anti-money laundering program to consider such factors as the types of activities and operations the adviser conducts, where it is located, who are its customers, and the nature of the adviser's international activities. Obtaining reliable Client information is critical to an advisory firm's ability to have an effective anti-money laundering program.

Responsibility

The Adviser’s Custodians shall act in the capacity as Anti-Money Laundering Officer (AML Officer) and be responsible for the implementation and monitoring of Anti-Money Laundering Policy and Procedures, including associated practices, disclosures and recordkeeping, that the Adviser is relying upon for these requirements (as such requirements are not mandatory for any RIA).

Procedure

Adviser has adopted the Custodians’ various procedures to implement by extension, the Adviser’s Anti-Money Laundering policy. In general, such procedures are as follows:

DETECTING & PREVENTING MONEY LAUNDERING

These procedures are designed to ensure that Adviser minimizes the opportunity for Clients to engage in money laundering activities through investments through Adviser. Adviser and its Covered Persons will take reasonable steps to identify and detect any suspicious activity.

PROHIBITED TRANSACTIONS

Neither Adviser nor any of its Covered Persons will engage in any transaction or provide services that assist a Client with any transaction that involves money laundering. No Covered Person shall participate in or facilitate a transaction with individuals, entities and jurisdictions identified by the Office of Foreign Assets Control, including those individuals on OFAC's SDN List.

SUSPICIOUS ACTIVITIES

Suspicious activity includes:

• a transaction that a Covered Person knows or suspects to involve proceeds from an illegal activity;

• a currency transaction that evades reporting requirements;

• a transaction that varies significantly from the Client's normal investment activities; Atria Investments, LLC Compliance Manual 96

• a transaction that has no business or apparent lawful purpose and Adviser knows of no reasonable explanation for the transaction after examining the available facts, including the background and possible purpose of the transaction;

• frequent wires in and out of a Client's account where such activity is abnormal for the account;

• a request to wire money to an OFAC blocked country;

• several separate deposits received within a short span of time on a recently opened account;

• multiple accounts under a single name or multiple names, with a large number of inter-account transfers;

• high level of account activity with low level of securities transactions;

• large wire transfers immediately followed by withdrawal by check or ACH;

• Client appears to act as an agent for an undisclosed principal;

• Client directed transactions involving a large dollar amount;

• transactions that lack business sense or that are inconsistent with the Client's investment strategy;

• Client exhibits unusual concern for secrecy, particularly with respect to his or her identity, type of business, and assets;

• Client's account indicates large or frequent wire transfers;

• Client or beneficiary has a questionable reputation; and

• Client has difficulty explaining the nature of his or her business.

Although the majority of these issues are within the scope of the custodial relationship, which is separate from Adviser’s Client relationship, it is still incumbent upon Adviser to monitor and take note of suspicious activity occurring within the account and to notify the Broker-Dealer/Custodian and governmental authorities of its suspicions as appropriate.

Investment advisers currently are not required to file a Suspicious Activity Report (SAR) related to a transaction (separately or in the aggregate) involving funds or assets of $5000 or more. However, an adviser may voluntarily make such a filing. If Adviser elects to make SAR filings, it will file a SAR promptly with the U.S. Department of Treasury in one or more of the following situations:

• Adviser detects any known or suspected federal criminal violation involving the Client; or

• Adviser knows, suspects or has reasons to suspect that the transaction (i) involves proceeds from an illegal activity; (ii) is designed to evade currency transaction reporting requirements; or (iii) has no business or apparent lawful purpose and Adviser knows of no reasonable explanation for the transaction after examining the available facts, including the background and possible purpose of the transaction.

SANCTIONS

If a Covered Person fails to comply with Adviser's Anti-Money Laundering Program, he or she may be subject to disciplinary action that includes suspension or termination. In addition, Adviser will report serious violations to the appropriate law enforcement authorities, which could potentially result in civil and criminal penalties, imprisonment, fines and forfeiture of property.