The ClearingPoint recognizes the risk of Money Laundering to its business and has adopted an Anti-Money Laundering and Counter-Terrorist Financing (“AML”) policy designed to achieve international best-practice standards within the financial services sector whilst taking into account all relevant national legislation in the jurisdictions within which the company operates. The Company’s AML general principles address the risk of Money Laundering through 3 core activities:

• Know Your Customer (KYC) checks;

• Currency Transaction Reporting (CTRs); and

• Suspicious Activity Reporting (SARs)

The Company’s AML policy has been created and is maintained through 4 broad methodologies:

• Designating an AML compliance officer;

• Developing internal policies, procedures, and controls ;

• Conducting on-going employee training programs; and

• Performing independent audit functions to test program

The ClearingPoint does not work in or with jurisdictions listed by the Financial Action Task Force as High-risk and non-cooperative jurisdictions http://www.fatf-gafi.org/countries/#high-risk.

The ClearingPoint does not transact with individuals or companies associated to any listing within prescribed sanctions lists, and the Company actively screens such lists including but not limited to those of UK Treasury, United Nations, European Union, and US Office of Foreign Assets Control (OFAC).

For further information on The ClearingPoint Compliance processes – please contact compliance@theclearingpoint.com