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Policy Statement Fenix Capital Management, LLC ("FCM") recognizes that The International Money Laundering Abatement and Anti- Terrorist Financing Act of 2001 (“Act”) imposes important new obligations on all financial firms for the detection, deterrence and reporting of money laundering activities. Under the Act, money laundering is defined as any financial transaction using income derived from criminal activity including, but not limited to, drug trafficking, fraud, illegal gambling and terrorism. FCM has established the following policies to ensure thorough compliance with all laws and regulations regarding money laundering. Prior to the opening of any new account, FCM shall document the identity, nature of business, income, source of assets, and investment objectives of each prospective customer. Accounts for persons or entities from countries that do not cooperate with the Financial Action Task Force (FATF) guidelines on money laundering shall be subject to a heightened level of scrutiny. Accounts in the name of, or related to, any person or entity on the Office of Foreign Asset Control (OFAC) Specially Designated Nationals and Blocked Person list shall not permitted. On an ongoing basis, FCM shall review account activity for evidence of suspicious transactions that may be indicative of money laundering activities. This review may include surveillance of: 1) money flows into and out of accounts, 2) the origin and destination of wire transfers, 3) non-economic transactions, and 4) other activity outside the normal course of business. Every officer, employee and associated person (“AP”) of FCM shall be responsible for assisting in the firm’s efforts to uncover and report any activity that might constitute, indicate or raise suspicions of money laundering. To this end, FCM shall provide continuing education and training of all such persons. Should any officer, employee or AP of FCM have any knowledge, suspicions or information regarding potential money laundering activities, that individual shall immediately notify FCM,s Compliance Department. FCM’s Compliance Officer shall document the reported activity, investigate fully, and, if warranted, report such activity to the senior management of FCM. FCM shall comply with all trade and economic sanctions imposed by OFAC against targeted foreign countries and shall cooperate fully with government agencies, self-regulatory organizations and law enforcement officials. As provided by the Act, FCM may supply information about former, current or prospective customers to such bodies. Any officer, employee or AP who fails to comply with FCM’s policies and procedures on money laundering may be subject to disciplinary action, including termination of employment. In addition, such failure may expose the individual to civil and criminal penalties under the Act. |
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FENIX CAPITAL MANAGEMENT, LLC, 12890 S.W.VILLAGE PARK LANE, TIGARD OR 97223, U.S.A.
E-MAIL: admin@fenixcapitalmanagement.com FAX: 1.503.213.8896 TEL: 1.512.532.7475
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Fenix Capital Management,LLC (“FCM”) DISCLAIMER Users: The FCM web site contains information about investments in FOREX trading and FOREX managed trading accounts. As such, access to the information contained herein may be restricted by laws and regulations applicable to the user. This information is not intended to be published or made available to any person in any jurisdiction where doing so would result in contravention of any applicable laws or regulations. In particular, certain investments can be marketed in certain jurisdictions only. The user should ensure that the use of this information and the making of any investment as a result does not contravene any such restrictions. It is the user's responsibility to be informed and to observe all applicable laws and regulations of any relevant jurisdiction. The information contained within the FCM web site does not constitute an offer or solicitation to sell or buy FOREX contracts , by anyone in any location in which such offer, solicitation, or distribution would be unlawful or in which the person making such offer or solicitation is not qualified to do so, or to anyone to whom it is unlawful to make such offer or solicitation. Any user distributing information taken from this site, in whatever form, to any other person, agrees to attach a copy of this page and obtain the agreement of such other person to comply with the terms set forth on this page. Applications to invest in any program listed on FCM's web site must only be made on the basis of the offer document relating to the specific investment (e.g. Risk disclosure, prospectus, investment memorandum, or other applicable terms and conditions). All users should consult an appropriate professional advisor as to whether they require any governmental or other consents, or need to observe any formalities to enable them to invest in any particular fund. If you are unsure about the meaning of any of the information contained within the FCM web site, please consult a professional advisor. FCM, or any of its information providers, licensees, directors, employees, or agents does not make any warranty as to the results to be obtained from use of this website or the investment opportunities presented on this web site. This web site and investment opportunities within this web site are distributed without warranties of any kind, either expressed or implied. Neither FCM nor anyone else involved in creating, producing, or delivering the web site or information herein shall be liable for any direct, indirect, incidental, special, or consequential damages arising out of use of the web site or inability to use the web site. FCM will not in any way be responsible for any selection or retention of, or the acts or omissions of, the user in connection with this web site. RISK WARNING THE RISK OF LOSS IN TRADING FOREX CAN BE SUBSTANTIAL. YOU SHOULD THEREFORE CAREFULLY CONSIDER WHETHER SUCH TRADING IS SUITABLE FOR YOU IN LIGHT OF YOUR FINANCIAL CONDITION. PAST PERFORMANCE IS NOT NECESSARILY INDICATIVE OF FUTURE RESULTS. THERE IS RISK OF LOSS IN FOREX TRADING. TRADEMARKS AND COPYRIGHTS Except as otherwise noted, the content of this website, including, but not limited to text, graphics and icons, are copyrighted materials of FCM Copyright ©2004, by FCM or its affiliates. All Rights Reserved, and may not be used or reproduced without prior written consent of FCM. Trademarks, logos and service marks on this site are owned by FCM, used by FCM under licenses from the owners of such marks or are the property of third parties. Use of such marks without the prior written consent of FCM or such third parties is prohibited. |