ANTI-MONEY LAUNDERING AND COMPLIANCE

Pursuant to Luxembourg laws and regulations, in particular the Luxembourg law of 19 February 1973 (as amended) intended to combat drug dependence, the law of 5 April 1993 (as amended) on the financial sector and the law of 12 November 2004 (as amended) concerning the fight against money laundering and the financing of terrorist activities, Circular 11/529, Circular 13/556 and CSSF regulation no. 12-02 of 14 December 2012, obligations have been imposed to prevent the use of undertakings for collective investment for money laundering purposes.


This identification procedure must be complied with by the General Partner (or the relevant competent agent of the General Partner) in the case of direct ccommitments to the SLP, and in the case of commitments received by the SLP from any intermediary resident in a country that does not impose on such intermediary an obligation to identify investors equivalent to that required under Luxembourg laws and regulations for the prevention of money laundering, as stipulated by the Financial Action Task Force (FATF).


In respect of the above, the General Partner (or the relevant competent agent of the General Partner) may require the person who makes a commitment to provide it with any documentation deemed necessary in the General Partner's judgment to satisfy its above referred obligations (or in the judgement of the relevant competent agent of the General Partner).


Failure to provide proper documentation may lead to the refusal of the General Partner to accept the prospective Investor's Commitment and/or to register the Investor as Shareholder and/or may result in the withholding of distributions and redemption proceeds by the SLP.


Any information provided to the SLP in this context is collected for anti-money laundering compliance purposes only.


Each Limited Partner hereby acknowledges and understands that the Company seeks to comply with all applicable laws concerning money laundering, terrorist financing and similar activities.


In furtherance of such efforts, such Limited Partner hereby represents and agrees that, to the best of such Limited Partner’s knowledge based upon appropriate diligence and investigation:

  • None of the cash or property that is paid or contributed to the Company by such Limited Partner shall be derived from, or related to, any activity that is deemed criminal under European Union laws and;
  • No contribution or payment to the Company by such Limited Partner shall (to the extent that such matters are within such Limited Partner’s control) cause the Company or the General Partner to be in violation of European Union laws in relation to anti-money laundering and all signatories hereto shall comply with requests of the Company notaries and service providers in connection with such legislation, as well as any legislation relating to the United States FATCA or the Global Information Exchange initiative.


Each Limited Partner shall promptly notify the General Partner if any of the foregoing shall cease to be true and accurate with respect to such Limited Partner.


Each Limited Partner hereby agrees to provide to the General Partner any additional information regarding such Limited Partner deemed necessary or convenient by the General Partner to ensure compliance with all applicable laws concerning money laundering, terrorism financing and similar illicit activities as well as tax evasion.


Each Limited Partner understands and agrees that the Company or the General Partner may release confidential information about such Limited Partner and, if applicable, any underlying beneficial owners, to proper authorities if the General Partner, in its sole discretion, determines that it is in the best interests of the Company or its affiliates in light of relevant rules and regulations under the laws set forth above.


Each Limited Partner understands and agrees that, if at any time it is discovered that any of the foregoing