Neuberger Berman BD LLC (“Neuberger Berman”) is a member of the Financial Industry Regulatory Authority (“FINRA”), the Securities Investor Protection Corporation (“SIPC”) and is regulated by the United States Securities and Exchange Commission and FINRA. Neuberger Berman is fully committed to complying with all statutory and regulatory requirements designed to combat money laundering, any activity which facilitates the funding of terrorist or criminal activities, including but not limited to the Bank Secrecy Act and the USA PATRIOT Act, and the prohibitions on dealing with sanctioned parties. We hereby confirm that we have policies and procedures in place designed to comply with applicable anti-money laundering laws and regulations in our jurisdiction, including the USA PATRIOT Act, and with the laws and regulations of any other jurisdictions applicable to our activities, including but not limited to Canada, the Cayman Islands, or Luxembourg.
In order to comply with these obligations, Neuberger Berman maintains and implements comprehensive policies and procedures related to anti-money laundering (AML), know your client (“KYC”), and sanctions laws.
Neuberger Berman’s AML policies and procedures include:
- the establishment of a comprehensive AML compliance program approved by Senior Management;
- the development of policies, procedures, and controls to achieve compliance with the applicable provisions of the Bank Secrecy Act and the USA PATRIOT Act;
- the establishment of an independent audit function to annually evaluate Neuberger Berman’s AML program;
- the designation of an AML officer to oversee the money laundering prevention efforts of Neuberger Berman;
- AML training of and certification by employees;
- Understanding the nature and purpose of customer relationships, including the ongoing monitoring of such relationships;
- due diligence and enhanced due diligence procedures for politically exposed persons, foreign banks and other high-risk customers;
- compliance with the prohibition from doing business with or on behalf of “shell banks”; and
- the development and utilization of technology to assist in the monitoring of transactions for the purpose of identifying and reporting suspicious activity and/or transactions.
Neuberger Berman’s KYC policies and procedures include:
- the establishment of a customer identification program included within Neuberger Berman’s AML compliance program;
- verifying the identity of any person seeking to open an account, to the extent reasonable and practicable, where required by law;
- verifying the identity of beneficial owners and controlling persons of entities seeking to open an account, as is required by applicable law;
- identifying the source(s) of funds of persons seeking to open an account where required by applicable law;
- maintaining KYC documents for a period not less than five years, or as otherwise mandated by applicable law;
- determining whether a customer appears on any lists of known or suspected terrorists or terrorist organizations provided to broker dealers by any government agency; and
- providing notice to customers that information may be requested in the process of verifying their identities.
Neuberger Berman’s Sanctions policies and procedures include:
- adherence with sanctions restrictions and prohibitions enacted by the U.S. Department of Treasury’s Office of Foreign Asset Control; the U.K. HM Treasury’s Office of Financial Sanctions Implementation; the E.C. Financial Stability, Financial Services and Capital Markets Union; and the U.N. Security Counsel (collectively, the “Sanctions”);
- not conducting business activity in any comprehensively sanctioned territories;
- procedures for screening clients and counterparties, including known beneficial owners, against the Sanctions lists and programs and/or for other adverse news; and
- blocking or freezing of any assets as required under the Sanctions lists and programs.