Effective Date: September 16, 2025
Company: Investorm Fund (“Investorm,” “we,” “our,” “us”)

1. Purpose

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy (“Policy”) is designed to prevent, detect, and report money laundering, terrorist financing, fraud, and other unlawful activities in connection with Investorm’s services. We are committed to operating in full compliance with international best practices, including FATF Recommendations, as well as applicable laws and regulations in the jurisdictions where we operate.

2. Scope

This Policy applies to all Clients of Investorm, including individuals, institutions, and corporate entities. It governs:

• Identity verification and onboarding procedures.

• Monitoring of deposits, withdrawals, and allocations into Fund Strategies.

• Ongoing compliance reviews, risk assessments, and regulatory reporting.

3. AML Compliance Framework

Our AML program is built on the following pillars:

• Internal Policies: Documented standards and escalation protocols to identify and mitigate financial crime risks.

• Employee Training: Regular staff training on AML/KYC obligations, typologies, and red-flag indicators.

• Transaction Monitoring: Continuous review of deposits, withdrawals, and capital movements using automated tools and manual oversight.

• Suspicious Activity Reporting (SAR): Timely filing of SARs with relevant authorities when required.

• Independent Audit: Annual review of the AML framework by an external compliance specialist.

4. KYC Procedures

         For Individuals:

• • Government-issued photo identification (passport, driver’s license, or national ID).

  • Proof of residential address (utility bill, bank statement, or equivalent issued within the last 90 days).

         For Legal Entities:

• • Certificate of incorporation or equivalent registration.

  • Proof of registered address.

  • Identification of Ultimate Beneficial Owners (UBOs) holding 25% or more ownership.

  • Verification of authorized signatories.

         Ongoing Monitoring:

• • Periodic re-verification (at least every 12 months).

  • Trigger-based reviews upon significant transactions, risk alerts, or material changes in ownership.

5. Transaction Monitoring

Investorm applies real-time and post-trade monitoring to identify unusual or high-risk activity, including:

• Large, rapid, or inconsistent transactions relative to a Client’s profile.

• Transactions involving high-risk jurisdictions or sanctioned entities.

• Structuring of transactions to avoid reporting thresholds.

• Connections to darknet, fraud, or other prohibited activity.

6. Suspicious Activity Reporting (SAR)

When suspicious activity is detected, Investorm will:

1. Escalate the case internally for investigation.

2. Freeze or restrict the account if necessary.

3. File a SAR with the relevant financial intelligence unit (e.g., FinCEN, FCA, DFSA), where legally required.

4. Avoid tipping-off Clients, in compliance with AML confidentiality obligations.

7. Prohibited Activities

Clients are strictly prohibited from using Investorm services for:

• Money laundering or terrorist financing.

• Transactions involving sanctioned countries, individuals, or entities.

• Fraud, tax evasion, or illicit financial flows.

• Circumvention of AML/KYC requirements.

Violations may result in immediate account suspension, fund forfeiture, and reporting to competent authorities.

8. Recordkeeping

• Investorm maintains KYC documentation, transaction data, and compliance reports for at least five (5) years after account closure or transaction completion.

• Records are stored securely and accessible only by authorized compliance personnel.

9. Risk-Based Approach

Investorm applies a risk-based approach (RBA):

• Low-risk Clients: Standard due diligence.

• High-risk Clients (e.g., PEPs, complex corporate structures, FATF high-risk jurisdictions): Enhanced Due Diligence (EDD), including source-of-funds checks and senior management approval.

• Ongoing risk reviews are conducted annually or as required by trigger events.

10. Cooperation with Authorities

Investorm fully cooperates with regulators, law enforcement, and other competent authorities in the investigation of suspected financial crime. Clients expressly authorize Investorm to disclose information when legally obligated.

11. Amendments

This Policy may be updated to reflect legal, regulatory, or operational changes. Updates will be published on investorm.fund with the revised effective date. Material changes will be communicated to Clients in advance, unless urgent compliance action is required.

12. Contact Information

Compliance Department – Investorm Fund

• Email: compliance@investorm.fund

• Phone: +1 (972) 200-4894

• Hours: Monday – Friday, 9:00 AM – 5:00 PM MDT
  We aim to respond to compliance inquiries within 48 hours.

13. Acknowledgment

By registering, investing, or using Investorm’s services, you confirm that you:

• Have read and understood this AML/KYC Policy.

• Agree to comply with its requirements.

• Accept that failure to comply may result in account suspension, closure, or regulatory reporting.