Anti-Money Laundering, Know-Your-Customer & Counter-Terrorist-Financing Policy

Gliese Capital LLC ("Gliese Capital," "the Firm," "we," "us," or "our")

Effective as of the date shown in the website footer. This Policy is reviewed and updated periodically; the version in force is the one published on this website.

1. Purpose and Scope

Gliese Capital is committed to preventing money laundering, terrorist financing, sanctions evasion, bribery, and other financial crime across every jurisdiction in which it operates, including the United Kingdom, the United Arab Emirates, Kazakhstan / the Astana International Financial Centre (AIFC), and the United States.

This Policy summarises the Firm's risk-based anti-money-laundering (AML), know-your-customer (KYC), and counter-terrorist-financing (CTF) framework. It applies to all of the Firm's officers, employees, contractors, and authorised introducers, and to all prospective and existing investors in funds and vehicles managed or advised by the Firm (each, a "Fund").

The Firm applies a group-wide standard calibrated to the highest common denominator of the regimes that apply to it. This Policy is a summary of internal controls; it is not legal advice, does not create third-party rights, and does not form part of any Fund's offering terms. Where this Policy and a Fund's offering documents differ as to investor obligations, the offering documents and subscription documents control.

2. Legal and Regulatory Framework

The Firm's framework is designed to align with the AML/CTF and sanctions regimes applicable to it, which may include:

United States — Bank Secrecy Act (BSA) / FinCEN. FinCEN has adopted a rule that would treat certain registered and exempt reporting investment advisers as "financial institutions" subject to AML/CFT programme and suspicious-activity-reporting obligations. The effective date of that rule has been postponed to 1 January 2028, and FinCEN has reopened it for further tailoring. The Firm is building toward compliance ahead of that date and does not represent that it currently has U.S. suspicious-activity-reporting obligations under that rule. U.S. sanctions administered by OFAC apply independently of, and regardless of, that timeline. **
United Kingdom. The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), the Proceeds of Crime Act 2002, and the Terrorism Act 2000, together with JMLSG guidance, under FCA / HMRC supervision. **
United Arab Emirates / Dubai. The applicable UAE federal AML/CFT decree-law and, where relevant, the rules of the DIFC and the Dubai Financial Services Authority. **
Kazakhstan / AIFC. The AML/CFT law of the Republic of Kazakhstan as applied through the AIFC AML/CTF and Sanctions Rules and related Rules of Internal Control, supervised by the Astana Financial Services Authority (AFSA). **
International baseline. The Financial Action Task Force (FATF) Recommendations serve as the common international standard underpinning this Policy.

3. Risk-Based Approach

The Firm maintains a documented, firm-wide business risk assessment covering investor, product, transaction, delivery-channel, and geographic risk. Given the Firm's footprint across Central Asia / the CIS and South America, geographic risk is treated as inherently elevated. Investors are risk-tiered (for example, low / medium / high), and the intensity of due diligence is calibrated to the assessed risk and periodically reassessed.

4. Customer (Investor) Due Diligence (CDD)

Before accepting subscription funds or completing onboarding, the Firm identifies and verifies each prospective investor using reliable, independent sources:

Individuals: full legal name, date of birth, nationality, residential address, and government-issued identification.
Entities: legal name, legal form, registration number, registered and principal address, constitutional documents, authorised signatories, and regulated-status or listing checks where applicable.
Relationship purpose: the nature and intended purpose of the investment, and confirmation of the investor's eligible / accredited-investor status consistent with the relevant Fund's offering exemption.
Non-face-to-face onboarding controls, given the cross-border investor base.

Where permitted, the Firm may rely on a regulated third party or fund administrator to perform elements of CDD, but the Firm retains ultimate responsibility. **

5. Beneficial Ownership

The Firm identifies, and takes reasonable measures to verify, the ultimate beneficial owners (UBOs) of entity investors — including individuals who own or control above the applicable threshold (commonly 25%, lower where risk warrants) and any person exercising ultimate effective control.
For trusts, foundations, nominee, layered, or offshore structures, the Firm maps the ownership and control chain and identifies settlors, trustees, protectors, and beneficiaries.
The Firm's collection of investor UBO information for KYC is separate from any U.S. Corporate Transparency Act (CTA) reporting obligation. Under FinCEN's March 2025 interim final rule, U.S.-formed entities and U.S. persons are exempt from CTA beneficial-ownership reporting; only foreign-formed entities registered to do business in a U.S. state remain "reporting companies." This affects the filing posture of the Firm's own or portfolio entities, not its duty to perform investor KYC. **

6. Source of Funds and Source of Wealth

Source of funds: the Firm establishes the origin of the specific subscription monies and the account and route by which they arrive. Subscriptions are generally accepted only from accounts in the investor's own name. **
Source of wealth: the Firm establishes how the investor accumulated overall wealth, with documentary corroboration required for higher-risk, larger, or frontier-linked investors.
Heightened source-of-funds and source-of-wealth scrutiny is applied given the Firm's frontier-market investor base and its activity in the resources, energy, and real-estate sectors, which are associated with elevated illicit-finance risk.

7. Enhanced Due Diligence (EDD)

EDD is applied where higher risk is identified, including for high-risk investors; politically exposed persons and their family members and close associates; investors connected to high-risk third countries or FATF-listed jurisdictions; and complex, opaque, or unusual ownership structures. EDD measures include senior-management approval to onboard or continue the relationship, additional identity and source-of-funds/source-of-wealth corroboration, examination of the background and purpose of the relationship, adverse-media and litigation screening, and enhanced ongoing monitoring. Given the Firm's Central Asia / CIS and South American footprint, a significant proportion of relationships are treated as presumptively elevated-risk and subject to EDD-level scrutiny.

8. Politically Exposed Persons (PEPs)

The Firm operates procedures to determine whether an investor or a UBO is a domestic or foreign PEP, an international-organisation PEP, or a family member or known close associate of such a person. PEP relationships require EDD and senior-management approval, and EDD-level measures continue for at least the period required by applicable law (for example, at least 12 months after a person ceases to be a PEP under MLR 2017), and longer where risk warrants. Particular care is applied in Central Asia / CIS jurisdictions where state-linked wealth is more common.

9. Sanctions and OFAC Screening

The Firm screens all investors, UBOs, controllers, and (where feasible) counterparties against applicable sanctions lists — including the U.S. OFAC Specially Designated Nationals and sectoral lists, UK OFSI, EU, UN, and AIFC/AFSA lists — at onboarding and on an ongoing basis.
The Firm will not establish or maintain a relationship with a sanctioned person or a person in a prohibited jurisdiction, and applies asset-freeze, blocking, rejection, and return procedures, with prompt escalation on any positive or potential match.
The Firm expressly recognises the elevated sanctions exposure arising from its CIS / Central Asia footprint and resource-sector counterparties, including secondary-sanctions risk. This screening complements the geopolitical and sanctions risk factors in our Risk Disclosure Statement.

10. Ongoing Monitoring and Suspicious-Activity Reporting

The Firm monitors relationships and transactions for consistency with the investor's known profile, stated purpose, and source of wealth, and refreshes CDD on a risk-based cycle (for example, high-risk investors at least annually), with trigger-based reviews on material changes (new UBO, change of control, sanctions or PEP-status change, adverse media).
Internal concerns are escalated to the Money Laundering Reporting Officer (MLRO) / Nominated Officer, with protected internal reporting and a strict prohibition on "tipping off."
External reporting is made as required by each applicable regime — for example, suspicious-activity reports to the UK National Crime Agency under the Proceeds of Crime Act; suspicious-transaction reports to the Kazakhstan financial-monitoring authority via AIFC/AFSA channels; reports to the relevant UAE Financial Intelligence Unit; and reports to FinCEN in the United States as and when the investment-adviser rule becomes effective or otherwise applies.
The Firm may suspend, reject, or unwind a subscription pending review and will not complete any transaction that would constitute a prohibited act.

11. Prohibited and Restricted Clients

The Firm will not knowingly accept, and reserves the right to refuse or terminate, any relationship involving: sanctioned or blocked persons or those acting on their behalf; persons in embargoed or prohibited jurisdictions; shell entities with no demonstrable economic purpose; persons who refuse to provide required CDD/EDD information; persons whose source of funds or wealth cannot be satisfactorily established; and any person whose involvement would create unacceptable money-laundering, terrorist-financing, sanctions, or reputational risk. The Firm may take such action without liability and to the extent permitted by applicable law.

12. Record-Keeping and Retention

The Firm retains CDD/EDD records, identification evidence, source-of-funds and source-of-wealth documentation, screening results, monitoring records, and internal and external suspicious-activity reports. Records are retained for at least five (5) years after the end of the business relationship or the relevant transaction, consistent with MLR 2017 and FATF standards, and longer where a regime or regulator requires. Records are held securely, consistent with our Privacy Notice, and made promptly available to regulators and auditors on request. **

13. Governance, Training, and Independent Testing

The Firm appoints an MLRO / Nominated Officer with appropriate authority and resources, with senior-management accountability and board-level oversight.
All relevant personnel receive risk-based AML/CTF and sanctions training at onboarding and periodically, with completion recorded.
The AML programme is subject to periodic independent testing or audit.
The Firm is structuring its programme around the recognised pillars of a robust AML framework — a designated compliance officer, written internal policies and controls, ongoing training, independent testing, and risk-based customer due diligence — in readiness for the U.S. investment-adviser AML/CTF requirements taking effect on 1 January 2028.

14. Cross-Border Coordination and Group Standard

A single group AML policy is applied across the Firm's London, Dubai, New York, and Almaty offices, supplemented by local addenda that meet each regulator's specific requirements (including the AFSA Rules of Internal Control, MLR 2017, applicable DFSA/UAE rules, and the BSA/OFAC framework). Information is shared within the group consistent with applicable data-protection law, with consistent escalation lines to the group MLRO.

15. Investor Cooperation Expectations

Prospective and existing investors are expected to provide complete and accurate KYC information promptly, to cooperate with CDD, EDD, source-of-funds/source-of-wealth, and ongoing-monitoring requests, and to notify the Firm of material changes (for example, a change of beneficial ownership, control, or PEP or sanctions status). The Firm may decline to accept a subscription, defer onboarding, or refuse, suspend, or compulsorily redeem an interest where information is not provided or where required by law or to manage AML, sanctions, or reputational risk. Completion of subscription is conditional on satisfactory completion of all onboarding checks.

16. Updates and Contact

The Firm reviews and updates this Policy periodically. Questions regarding this Policy, or AML/compliance matters generally, may be directed to:

Gliese Capital LLC AML / Compliance: compliance@gliesecap.com General enquiries: info@gliesecap.com

This Policy should be read together with our Terms of Use, Privacy Notice, and Risk Disclosure Statement.

AML, KYC & Sanctions Policy