Anti Money Laundering ("AML")
Bellwether Capital actively complies with all anti-money laundering and anti-terrorism laws and regulations to the fullest extent that it can do so under all applicable foreign and domestic laws.
Bellwether Capital shall review account activity for evidence of suspicious transactions that may be indicative of money laundering activities. This review may include surveillance of: 1) money flows into and out of accounts, 2) the origin and destination of wire transfers, and 3) other activity outside the normal course of business.
Funds will be returned to the source account whenever possible, and to the same beneficial owner. Should a client request funds be returned to an account other than the source, the withdrawal will be processed at the discretion of Bellwether Capital Management LP.
Finally, in order to be fully compliant with applicable regulatory requirements, Bellwether Capital may occasionally reach out for additional information and/or documentation from clients.