Anti-Money Laundering & Know Your Customer Policy

SSL Management LLC ("Management Company") and SSL Fund LLC ("Fund") (collectively, the "Company") are committed to the highest standards of Anti-Money Laundering ("AML") and Counter-Terrorist Financing ("CTF") compliance. As Delaware limited liability companies operating a private investment fund, we maintain robust policies and procedures to prevent our Services from being used for money laundering, terrorist financing, or other financial crimes.

This policy applies to all directors, officers, members, employees, contractors, and agents of the Management Company and the Fund, as well as all investors and business relationships.

Our AML/KYC program is designed to comply with applicable laws and regulations, including:

• United States Federal Legislation:
  • Bank Secrecy Act (BSA)
  • USA PATRIOT Act
  • Anti-Money Laundering Act of 2020
  • Securities Act of 1933 and Securities Exchange Act of 1934
  • Investment Company Act of 1940 and Investment Advisers Act of 1940
• Delaware State Law:
  • Delaware Limited Liability Company Act
  • Delaware Securities Act
• Regulatory Requirements:
  • Financial Crimes Enforcement Network (FinCEN) regulations
  • Securities and Exchange Commission (SEC) rules and guidance
  • Office of Foreign Assets Control (OFAC) sanctions programs
• International Standards:
  • Financial Action Task Force (FATF) Recommendations
  • Wolfsberg Group Anti-Money Laundering Principles

We conduct Customer Due Diligence ("CDD") on all clients before establishing a business relationship and on an ongoing basis throughout the relationship.

We apply Enhanced Due Diligence ("EDD") measures for higher-risk clients and situations, including:

• Politically Exposed Persons (PEPs): Current or former senior government officials, their family members, and close associates;
• High-Risk Jurisdictions: Clients from countries identified as high-risk by FATF or other relevant bodies;
• Complex Structures: Clients with complex ownership structures or unusual business arrangements;
• High-Value Relationships: Relationships involving significant transaction volumes or values;
• Adverse Media: Clients with negative media coverage related to financial crime.

EDD measures may include additional documentation requirements, senior management approval, more frequent reviews, and enhanced monitoring of transactions and activities.

We conduct ongoing monitoring of all client relationships to ensure that:

• Client information remains accurate and up-to-date;
• Activities are consistent with our understanding of the client's business;
• Unusual or suspicious activities are identified and investigated;
• Risk assessments are reviewed and updated as appropriate;
• Sanctions screening is performed on an ongoing basis.

Clients are required to notify us promptly of any material changes to their information, including changes in beneficial ownership, business activities, or contact details.

We maintain procedures for identifying, investigating, and reporting suspicious activities. Indicators of suspicious activity may include:

• Unusual transaction patterns inconsistent with the client's profile;
• Reluctance to provide required information or documentation;
• Provision of false or misleading information;
• Transactions with no apparent business purpose;
• Connections to high-risk jurisdictions without clear business rationale;
• Attempts to avoid reporting thresholds;
• Adverse media or negative information about the client.

We maintain a comprehensive sanctions compliance program that includes:

• Screening: All clients, beneficial owners, and connected parties are screened against applicable sanctions lists, including:
  • United Nations Security Council Consolidated List
  • US Office of Foreign Assets Control (OFAC) Lists
  • UK HM Treasury Sanctions List
  • European Union Consolidated List
  • Other applicable jurisdictional sanctions lists
• Ongoing Monitoring: Continuous screening against updated sanctions lists;
• Prohibited Activities: We do not engage in any transactions or business relationships with sanctioned individuals, entities, or countries;
• Escalation: Any potential sanctions matches are immediately escalated to the Compliance Officer for investigation.

We maintain comprehensive records in accordance with regulatory requirements:

• Client Records: All CDD documentation, including identification documents, verification records, and risk assessments;
• Transaction Records: Details of all transactions and activities;
• Correspondence: All relevant communications with clients;
• Internal Reports: Suspicious activity reports and investigation records;
• Training Records: Documentation of staff training and certifications.

Records are retained for a minimum of five (5) years after the termination of the business relationship or completion of the transaction, or longer if required by law.

Our AML/KYC program is overseen by the following governance structure:

• Board of Managers: Ultimate responsibility for AML/CFT compliance;
• Chief Compliance Officer (CCO): Designated officer responsible for receiving and assessing internal suspicious activity reports and filing SARs with FinCEN;
• Deputy CCO: Designated to act in the absence of the CCO;
• AML Compliance Officer: Day-to-day oversight of the AML/KYC program;
• AML Compliance Committee: Regular review of policies, procedures, and emerging risks.

All relevant personnel receive comprehensive AML/CFT training, including:

• Initial training upon joining the Company;
• Annual refresher training;
• Updates on regulatory changes and emerging risks;
• Role-specific training for client-facing and compliance staff;
• Training on recognizing and reporting suspicious activities.

Training records are maintained and reviewed to ensure all personnel remain current on their obligations.

By using our Services, clients agree to:

• Provide accurate and complete information during onboarding and throughout the relationship;
• Promptly notify us of any changes to their information;
• Cooperate with our due diligence and verification processes;
• Not use our Services for any illegal purpose, including money laundering or terrorist financing;
• Maintain their own AML/CFT compliance programs where applicable;
• Provide additional information or documentation upon request.

Failure to comply with these obligations may result in suspension or termination of Services and reporting to relevant authorities.

In accordance with the Corporate Transparency Act and FinCEN beneficial ownership reporting requirements, we maintain comprehensive records of beneficial owners and persons exercising control over client entities. This information is:

• Collected during the onboarding process and updated annually;
• Maintained in secure, segregated systems with restricted access;
• Disclosed to regulatory authorities upon request;
• Protected from unauthorized disclosure in accordance with applicable law.

The Company maintains comprehensive sanctions and proliferation financing screening procedures in accordance with OFAC regulations and other applicable laws. We screen all clients and transactions against:

• UN Security Council Consolidated Sanctions List;
• US OFAC Specially Designated Nationals List;
• EU Consolidated List of Persons, Groups and Entities;
• UK HM Treasury Sanctions List;
• Other applicable international sanctions lists.

Any potential matches are immediately escalated and investigated. Transactions involving sanctioned parties are prohibited and reported to relevant authorities.

The Company fully cooperates with regulatory authorities and law enforcement agencies. We maintain procedures for:

• Responding to regulatory inquiries and information requests;
• Providing documentation and records as required by law;
• Participating in regulatory examinations and audits;
• Reporting suspicious activities and potential violations;
• Complying with court orders and legal process.

For questions regarding this policy or to report concerns, please contact: