AML & Sanctions Policy

AceStone maintains a written anti-money laundering ("AML") program designed to prevent its business activity and financial relationships from being used to facilitate money laundering, terrorist financing or other financial crime under applicable U.S. law. The program includes:

• a designated AML Compliance Officer with responsibility for program oversight;
• internal controls governing counterparty screening, transaction review and escalation;
• risk-based due diligence applied to sellers, buyers, capital partners and other counterparties;
• ongoing monitoring of transactions for indicators of suspicious activity;
• periodic training of personnel on AML obligations and red-flag recognition; and
• independent review of the program's adequacy and effectiveness.

AceStone complies with sanctions programs administered by the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC"). Counterparties are screened against the Specially Designated Nationals and Blocked Persons List and other applicable restricted-party lists before the Firm enters into a transaction. The Firm does not transact with, or on behalf of, any sanctioned person, entity or jurisdiction.

3.1 Before entering into a material transaction, the Firm conducts risk-based due diligence proportionate to the nature, size and structure of the proposed transaction. This may include identity verification, review of beneficial ownership and control, assessment of source of funds, and evaluation of the transaction's consistency with the counterparty's stated purpose.

3.2 The Firm may request additional information where enhanced review is warranted and may decline to proceed where such information is not provided.

AceStone does not accept or facilitate transactions where the source of funds appears irregular, counterparty identity cannot reasonably be established, or the proposed structure raises material compliance concerns. Such transactions may be paused, escalated or declined at the Firm's discretion.

The AML Compliance Officer reviews and escalates any counterparty or transaction presenting indicators of money laundering, fraud or other financial crime. Where escalation is warranted, the Firm will take appropriate action, which may include declining to proceed and, where legally required, reporting to the relevant authorities.

The Firm maintains records of its transactional activity, counterparty information and compliance reviews in accordance with applicable recordkeeping requirements, retained for periods consistent with applicable law and the Firm's banking and compliance obligations. Personal information within those records is handled as described in the Firm's Privacy Policy.

This Policy is reviewed at least annually, and more frequently where warranted by changes in applicable law, regulatory guidance or the Firm's activities. The AML program is subject to periodic independent testing.

Compliance inquiries should be directed to: