AML, KYC, and Sanctions Policy
The firm's framework for customer identification, beneficial ownership verification, sanctions screening, suspicious activity reporting, and independent testing of the anti-money-laundering program.
- Policy Owner
- Chief Compliance Officer
- Approving Body
- Board of Directors
- Effective Date
- January 1, 2026
- Last Reviewed
- June 1, 2026
- Next Review
- January 1, 2027
- Version
- 1.0
Purpose
The Anti-Money Laundering, Know Your Customer, and Sanctions Policy establishes the firm's program for detecting and preventing money laundering, terrorist financing, sanctions violations, and other financial crime. The policy is designed to comply with the Bank Secrecy Act, the USA PATRIOT Act, the Office of Foreign Assets Control sanctions regulations, and applicable state and non-U.S. anti-financial-crime laws.
Scope
This policy applies to all funds, vehicles, and accounts managed or advised by MajorWave, LLC and its affiliates, to all Personnel of the firm, and to all subscriptions, distributions, redemptions, and secondary transfers involving limited partners of the funds.
Customer Identification and Verification
The firm applies a risk-based customer identification program to every prospective limited partner. Required documentation includes government-issued identification for individuals, formation documents and beneficial-ownership diagrams for entities, and current authority documentation for trustees and fiduciaries.
Beneficial Ownership
For each entity investor, the firm identifies all beneficial owners who directly or indirectly hold 25% or more of the entity, plus one control person, in accordance with the FinCEN Customer Due Diligence Rule. Documentation is refreshed at each material change of ownership.
Sanctions Screening
Every prospective investor, and every material counterparty of a portfolio company, is screened against the OFAC Specially Designated Nationals list, the OFAC Sectoral Sanctions Identification list, the EU Consolidated Sanctions List, and the UK HM Treasury Consolidated List at onboarding and on a rolling basis.
Enhanced Due Diligence
Enhanced due diligence is required for politically exposed persons, investors from higher-risk jurisdictions, investors using complex ownership structures, and any investor whose profile presents elevated financial-crime risk. Enhanced files are reviewed and approved by the Chief Compliance Officer.
Ongoing Monitoring
The firm monitors subscriptions, redemptions, secondary transfers, and material changes to investor documentation on an ongoing basis. Unusual activity is escalated to Compliance for review and, where appropriate, to counsel and to law enforcement.
Suspicious Activity Reporting
Suspicious activity, including transactions inconsistent with the investor profile, transactions structured to avoid reporting thresholds, or activity involving sanctioned or high-risk parties, is escalated to the Chief Compliance Officer. Where required, the firm files a Suspicious Activity Report with FinCEN.
Independent Testing
The AML program is independently tested at least annually by qualified internal audit staff or an external firm. Findings are reported to the Audit Committee and remediation is tracked to closure.
Training
All Personnel receive AML training at onboarding and annually thereafter. Training is tailored by role and includes sanctions, red-flag identification, and reporting obligations.
Recordkeeping
The firm retains all customer identification, sanctions screening, monitoring, and suspicious-activity records for a minimum of five years, or such longer period as applicable law requires.