Anti-Money Laundering

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Anti-Money Laundering/ Counter Terrorist Financing laws

The rules
The Federal Government has introduced the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) that regulates financial services and transactions in a way that is designed to detect and prevent money laundering and terrorism financing. The AML/CTF Act is regulated by the Australian Transaction Reports and Analysis Centre (AUSTRAC).

Under the AML/CTF Act, Millinium Capital Managers is required:

• to verify our clients' identities before providing services to them, and to re-identify them if we consider it necessary to do so; and
• where a client supplies documentation relating to the verification of their identity, we must keep a record of this documentation for 7 years

To ensure we comply with our obligations under the law, Millinium Capital Managers has be implemented a number of measures and controls including carefully identifying and monitoring investors.

Consequences of compliance
As a result of the implementation of our compliance program:

• transactions may be delayed, blocked, frozen or refused where Millinium Capital Managers has reasonable grounds to believe that the transaction breaches Australian law or sanctions or the law or sanctions of any other country;
• where transactions are delayed, blocked, frozen or refused Millinium Capital Managers is not liable for any loss an investor suffers (including consequential loss) as a result of our compliance with the AML/CTF Act as it applies to a fund; and
• Millinium Capital Managers may from time to time require additional information from an investor or indirect investor to assist us in this process.

Reporting Obligations to AUSTRAC
Millinium Capital Managers has certain reporting obligations pursuant to the AML/CTF Act. The legislation prevents us from informing an investor or indirect investor that any such reporting has taken place. Where legally obliged to do so, we may disclose the information gathered to regulatory and/or law enforcement agencies, including AUSTRAC and to other bodies, if required by law.

Completion of an application for investment
Each application form for investment, once signed by an investor, holds an investor to a number of representations and warranties, among other things, relating to matters which we must seek confirmation of in order to comply with the provisions of the AML/CTF Act. Please read these carefully before applying for interests in this fund. Each investor, such as an individual, company, trustee or partnership will need to provide us with specific information outlined in the application form for us to process and verify and re-verify their identity. Investors may use the AML forms provided on the website when completing an application form and provide these both to us. 

Please note: It may be a criminal offence to knowingly provide false or misleading information or documents when completing or making an application for investment.