US PATRIOT ACT

Under the USA PATRIOT Act and other regulations, White Mountain Capital must establish a compliance program, which includes policies and procedures to detect and report suspicious transactions to the government, as well as ensure compliance with the laws. White Mountain Capital must also implement specialized employee training programs, designate an anti-money laundering compliance officer and conduct independent testing of the effectiveness of the program. White Mountain Capital has appointed an anti-money laundering officer to direct the program. All of our employees are trained in anti-money laundering practices and procedures and the details of the firm’s policies.

The regulations have also imposed requirements on client information and verification of that information. White Mountain Capital is required to verify the identity of the clients with whom they do business, determine the source of funds in a client’s account and obtain the information about a client’s financial status. As part of our compliance with these new regulations and in support of the fight against money laundering around the world, we may ask clients for additional information and documentation about certain accounts and transactions. This information may be used to verify client identity.

If you have any questions regarding our anti-money laundering program, please contact your Account Executive.