Money laundering and financing terrorism has been identified as a major threat to the International financial services community. The Qatar Government, in common with Qatar Monetary Authority and Capital Market Authority (CMA) in Qatar, has passed legislation designed to prevent money laundering which imposes certain requirements upon institutions licensed in their jurisdiction.

As CB Asset Management LLC is registered, authorized and based in Qatar, Qatar legislation is of primary importance to the company. CB Asset Management LLC has adopted the Qatar requirements as a statement of the minimum standards to be adopted to minimize the use of its products and services for money laundering and terrorist financing.

Policy Objectives

The objectives of this Policy are:

• To prevent use of CB Asset Management LLC’s products or services for money laundering.
• To prevent damage to CB Asset Management LLC’s name and reputation by association with money launderers.
• To ensure that CB Asset Management LLC complies with money laundering legislation / regulations wherever it does business.

Policy Scope

Meeting the requirements of this Policy is considered of paramount importance and takes precedence over other commercial aspects of managing our customer relationships.

Policy Application

CB Asset Management LLC will implement policies and procedures to the standards required by the Qatar legislation (or to any higher standard required internationally), which will:

• Identify and know its customers.
• Ensure that adequate records are kept and preserved.
• Provide training for relevant employees to enable them to understand and fulfil their obligations under the Qatar legislation.
• Ensure suspicious transactions are reported to the Compliance Officer who will determine whether a report is to be made to the authorities and to the Qatar Financial Intelligence Unit FIU)...
• Provide the Compliance Officer with all reasonable access to information that may be of assistance to him/her in carrying his/her duties.
• Ensure that all necessary controls and communications are in place and are operating effectively to prevent money laundering.
• This Policy should always be read and operated in conjunction with CB Asset Management LLC’s detailed AML/CTF and KYC procedures.

Policy Ownership

The responsibilities connected with this Policy are:

• The overall ownership of this Policy rests with CB Asset Management LLC’s Compliance Committee.
• The day–to-day custodian of the Policy is the Anti-Money Laundering Compliance Officer who also controls the amendments required to this Policy as a result of changing internal and external requirements.
• The Anti-Money Laundering Compliance Officer is responsible for ensuring that all CB Asset Management LLC’s employees comply with this Policy.