Regulations

REGULATORY LICENSES

LOM Financial (Bermuda) Limited, LOM Asset Management Limited, Global Custody & Clearing Limited, and LOM Financial (Cayman) are regulated by and licensed to conduct Investment Business by the Bermuda Monetary Authority.

LOM Financial (Bahamas) Limited is regulated and licensed by the Securities Commission of the Bahamas.

ANTI-MONEY LAUNDERING / ANTI-TERRORIST FINANCING (“AML/ATF”) POLICY STATEMENT

LOM is strongly committed to preventing the use of its operations for money laundering or any activity which facilitates money laundering or the funding of terrorist or criminal activities. Accordingly, the Company will comply with all applicable laws and regulations designed to combat money laundering activity and terrorist financing as well as guidance notes applicable in Bermuda and The Bahamas.

Through policy guidelines, LOM is committed to:

• Have an AML policy that covers all businesses and customers of LOM
• Designate a person responsible for compliance with LOM’s AML policy
• Have procedures that require the collection of information in order to verify and identify each new customer
• Only accept clients whose identity is established by conducting due diligence appropriate to the risk profile of the client
• Monitor customers’ activity on an on going basis, as appropriate to the risk profile
• Record and maintain transactional customer data for the required period of time
• Provide regular anti-money laundering awareness training to staff and to include procedures for identifying unusual and potentially suspicious activity and reporting suspicious activity to competent authorities
• Cooperate with competent legal and regulatory authorities if so requested.
• Report suspicious activities to the appropriate local authorities.

The LOM Group has developed extensive Anti-Money Laundering/Anti-Terrorist Financing policies and procedures. It provides the basis to further develop specific policies and operational procedures within each business line, support function and geographic location to meet Group-wide standards.  The Head of Compliance monitors operations, and implements and enforces policies necessary to protect the firm and its clients. The Head of Compliance reports to senior management and the board of directors, and is responsible for the management of the firm’s overall compliance and AML risk.

Policy on US and Canadian Residents

• We can accept U.S. and Canadian citizens that are not resident in the U.S. or Canada
• We can accept corporate clients with US resident beneficiaries provided no US resident is a signatory
• US citizen and residents’ accounts are reportable under U.S. FATCA regulations (see FATCA details here.)
• We do not accept individual/joint accounts for U.S. or Canadian residents or entities.