Anti-Money Laundering (AML) Policy

Our Commitment to Compliance

Infinity⁹ Capital Asset Management, LLC (“Infinity⁹”) is fully committed to maintaining the highest standards of integrity and regulatory compliance. As a U.S.-based investment manager, we have adopted a comprehensive Anti-Money Laundering (AML) program designed to prevent the misuse of our investment platform for illicit purposes, including money laundering, terrorist financing, and other financial crimes.

Our policies and procedures are designed to comply with the Bank Secrecy Act (BSA), the USA PATRIOT Act, and all applicable regulations issued by the U.S. Department of the Treasury, the Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority (FINRA), and the Office of Foreign Assets Control (OFAC).

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Core Components of Our AML Program

Infinity⁹’s AML program is actively maintained and subject to regular testing. Key elements include:

• Customer Identification Program (CIP): We collect, verify, and retain information to form a reasonable belief about the identity of each investor, whether individual or entity.
• Customer Due Diligence (CDD): Each investor is assigned a risk profile, and we conduct enhanced due diligence (EDD) where warranted—especially for high-risk jurisdictions, complex structures, or politically exposed persons (PEPs).
• Transaction Monitoring: We monitor fund activity on a risk-adjusted basis and review for unusual or suspicious behavior. All activity is reviewed in accordance with the investor’s known profile and the intended use of funds.
• Suspicious Activity Reporting (SAR): We are required to file Suspicious Activity Reports with FinCEN when suspicious transactions are identified, consistent with 31 C.F.R. § 1023.320.
• Sanctions Screening: All clients and counterparties are screened against OFAC and other relevant global sanctions lists prior to onboarding and on an ongoing basis.
• Recordkeeping: We maintain all AML-related records in accordance with 31 C.F.R. § 1010.410 and applicable SEC rules.
• Employee Training: All relevant personnel undergo AML training at onboarding and annually thereafter. Our team is trained to identify red flags and escalate concerns appropriately.
• Independent Testing: Our AML program is subject to annual independent testing to ensure its adequacy, effectiveness, and alignment with evolving regulations.

Risk-Based Approach

Infinity⁹ applies a risk-based framework that aligns with the nature of our investor base and investment strategies. This includes:

• Assessing jurisdictional and investor-specific risk factors
• Verifying source of funds and source of wealth
• Applying enhanced due diligence where appropriate
• Regularly re-evaluating investor profiles as needed

This approach allows us to focus resources where the risk is highest and maintain a robust compliance posture without disrupting legitimate investment activity.

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Reliance and Third Parties

In certain cases, Infinity⁹ may rely on regulated fund administrators, custodians, or financial intermediaries to conduct aspects of AML compliance, including identification, verification, and monitoring, provided such reliance is permissible under applicable law and supported by contractual agreements. We conduct periodic oversight to validate their ongoing compliance.

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AML Standards Across Vehicles

All private funds, joint ventures, and special purpose vehicles (SPVs) managed by Infinity⁹ are subject to the same AML standards, regardless of their structure or domicile. This ensures consistency, transparency, and alignment with investor expectations.

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Prohibited Investors

Infinity⁹ does not conduct business with individuals or entities that:

• Appear on the OFAC Specially Designated Nationals (SDN) list or other restricted party lists
• Reside in, are organized under the laws of, or operate from countries subject to comprehensive U.S. sanctions
• Fail to provide sufficient AML documentation during onboarding

We reserve the right to refuse or terminate relationships that present excessive risk or noncompliance.

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Compliance Contact

For AML-related inquiries or requests for due diligence documentation, please contact our compliance department:

Compliance Officer
Infinity⁹ Capital Asset Management, LLC
801 Brickell Avenue, Suite 800
Miami, FL 33131
legal@infinity9.com

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Legal References

• Bank Secrecy Act (BSA) – 31 U.S.C. § 5311 et seq.
• USA PATRIOT Act – Pub. L. No. 107-56
• 31 C.F.R. § 1023.210 (AML Requirements for Investment Advisers)
• FINRA Rule 3310 (AML Compliance Program)
• OFAC Sanctions Programs and Guidelines

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