Fill and Sign the Fully Disclosed Clearing Agreement of Pershing Llc Secgov Form

-1 Exhibit M-1 Anti-Money Laundering Policy[Name of Fund Manager] (the "Company") is committed to a policy designed to prevent the misuse of its employees, facilities and investment fund clients by persons who seek to launder money. This policy applies to all investment funds (each, a "Fund" and collectively, the "Funds") managed or advised by the Company, except to the extent different procedures are specifically adopted by or for one or more of the Funds. As part of its policy, the Company has adopted procedures to help it detect money laundering and to prevent its occurrence. The Company's goal is to have each Fund accept capital contributions only from legitimate, law- abiding investors, to permit transfers of interests in the Funds only to such persons, and to have each Fund invest capital only in legitimate, law-abiding companies. The Company encourages its employees to bring questionable conduct to the attention of the General Counsel, who will act as the Company's compliance officer (the "Compliance Officer") and be in charge of the Company's anti-money laundering efforts. Any employee who knowingly fosters such illegal activity or who purposefully ignores plainly suspicious circumstances will be subject to inquiry and discipline. This anti-money laundering policy consists of three parts. The first part is an overview to help employees and others associated with the Company understand money laundering, how it works, and why it is important to help stop it. The second part outlines the Company's responsibilities to have an effective anti-money laundering system in place at all times. The third part consists of the actual specific requirements that the Company has determined all employees must follow. I. Overview of Money Laundering A. Money Laundering Covers a Wide Variety of SituationsMoney laundering may occur in connection with any financial transaction in funds derived from criminal activity, or any financial transaction designed to promote criminal activity or to invest, conceal or transfer its proceeds. -2 Illegal money laundering may relate to many types of criminal activities, including white-collar crimes such as fraud, insider trading, embezzlement, tax evasion, bribery, environmental violations, or in connection with illicit drug activities or funding terrorist activities identified by the U.S. Government. For purposes of money laundering, a "transaction" includes essentially any movement of funds. Money laundering is not limited to cash transactions, but also includes all forms of electronic transfers, including transfers of currency and securities. B. Stages of Money LaunderingThe laundering process is typically accomplished in three stages, which may comprise numerous transactions. Any one of these transactions or stages could involve the Company: