Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) Policy

1. Purpose

This Policy sets forth Gliese Capital's framework to:

• Prevent our services from being used for money laundering, terrorist financing, or other illicit activities.
• Comply with the Financial Action Task Force (FATF) Recommendations, as well as applicable U.S., U.K., and international AML/CTF regulations.
• Protect the integrity of global financial markets and maintain trust with clients, regulators, and counterparties.

2. Scope

This Policy applies to:

• All Gliese Capital employees, contractors, directors, and affiliates.
• All clients, counterparties, and third parties engaging with Gliese Capital.
• All business units, products, and services offered by Gliese Capital.

3. Regulatory Framework

Gliese Capital complies with, but is not limited to, the following frameworks and regulations:

• USA PATRIOT Act (U.S.)
• Bank Secrecy Act (BSA, U.S.)
• EU AML Directives (5AMLD / 6AMLD)
• UK Proceeds of Crime Act (POCA) & Money Laundering Regulations
• Financial Action Task Force (FATF) 40 Recommendations
• Applicable UN, OFAC, and EU sanctions regimes.

4. Know Your Customer (KYC) / Customer Due Diligence (CDD)

Gliese Capital implements a risk-based approach to customer verification, including:

• Individual Clients: Collection and verification of government-issued identification, proof of address, and source of funds.
• Institutional Clients: Verification of incorporation documents, beneficial ownership structures, authorized signatories, and regulatory licenses.
• Enhanced Due Diligence (EDD): Applied to high-risk clients, politically exposed persons (PEPs), or clients from high-risk jurisdictions.

5. Ongoing Monitoring

• Continuous monitoring of client transactions to ensure consistency with known customer profiles.
• Identification of unusual, complex, or suspicious transactions.
• Periodic refresh of KYC documentation, depending on client risk profile.

6. Sanctions Compliance

• All clients and transactions are screened against OFAC, EU, UN, and HM Treasury sanctions lists.
• Gliese Capital will not engage with individuals, entities, or jurisdictions subject to applicable sanctions.

7. Record-Keeping

• All KYC, CDD, and transaction records are retained for a minimum of five (5) years after the end of the client relationship or transaction, in compliance with applicable law.
• Records are maintained in secure, encrypted systems accessible only by authorized personnel.

8. Suspicious Activity Reporting

• Employees are required to escalate red flags to the AML Compliance Officer immediately.
• Gliese Capital will file Suspicious Activity Reports (SARs) or equivalent regulatory filings with the appropriate authorities, without notifying the client (tipping-off strictly prohibited).

9. Training & Awareness

All employees receive annual AML/CTF training covering:

• Identification of suspicious activity.
• Reporting obligations.
• Evolving typologies of financial crime.

Specialized staff receive enhanced training appropriate to their roles.

10. Independent Audit

Gliese Capital's AML/CTF program is subject to independent testing and audits to ensure ongoing compliance and effectiveness.

11. Roles & Responsibilities

• Board of Directors: Overall accountability for AML/CTF compliance.
• AML Compliance Officer (MLRO): Day-to-day oversight, policy enforcement, and regulatory reporting.
• Employees: Adherence to policy, reporting suspicious activity, and completing training requirements.

12. Zero-Tolerance Policy

Gliese Capital maintains a zero-tolerance policy toward financial crime. Any employee, client, or counterparty found to be in violation of AML/CTF rules will be subject to immediate termination of relationship and, where appropriate, reported to regulatory authorities.

13. Contact

For AML/CTF-related inquiries, please contact:

AML Compliance Officer
Gliese Capital LLC
Email: compliance@gliesecap.com