EFTA01394672.pdf

GLOUS140 Lawrence Hirsch Glendower Capital Secondary Opportunities Fund IV. LP Appendix 3 Anti-Money Laundering GENERAL ANTI-MONEY LAUNDERING CONSIDERATIONS The Manager takes seriously its responsibility to prevent the Fund from being used for money laundering or other illicit purposes. To comply with anti-money laundering laws, the Manager or any designee thereof may require a detailed verification of the identity and residence of each Investor (and each person who holds a beneficial interest in each Investor) and the source of the payment of the investment. Each of the Manager or its designee reserves the right to request such information as it considers necessary to verify the identity of any Investor (and each person who holds a beneficial interest in each Investor) and may also independently obtain such information. In the event of delay or failure by any Investor to produce any information required for verification purposes, the Manager or its designee may refuse to accept such Investors subscription for an Interest, and any funds received will be retumed to the account from which such funds were sent (unless such return is, in the judgment of the Manager or its designee, contrary to applicable law, regulation or the instructions of law enforcement officials, in which case the funds may be blocked or retained). If the Manager or its designee has a suspicion obtained in the course of business that any person is engaged in money laundering or other illegal activity, the Manager must. notwithstanding any obligations of confidentiality that might otherwise apply. report such suspicion to the appropriate authorities pursuant to applicable law. ANTI-MONEY LAUNDERING LEGISLATION In order to comply with applicable anti-money laundering legislation, the Manager has an obligation to ask each Investor questions regarding its identity, address, source of funds and, if necessary, legal representatives, authorized signatories, beneficial owners or control structures and to collect requisite documentation to substantiate the information. Also, enhanced anti-money laundering regulations require that should any of the above personal or institutional information change. such clients must immediately notify the Manager of the change(s) and provide the Manager with relevant documentation to verify these changes. ECONOMIC SANCTION REGULATIONS Each Investor will be required to make representations and warranties to the Manager that, among other things, the Interests to be purchased by the Investor will not be held by, or for the benefit of. any person currently subject to UK sanctions, UN sanctions, EU sanctions, and/or U.S. sanctions administered by the Office of Foreign Assets Control of the U.S. Treasury Department (collectively, the -Sanction Regulations"). The Manager and its designee may undertake their own efforts to verify the accuracy of any Investor's representations and warranties and, so long as an Investor holds an Interest, may seek to verify that neither the Investor nor any person holding a beneficial interest in the Investor is subject to any then-applicable Sanction Regulations. The Manager also may be required in the future to obtain additional disclosures from an Investor (and each of the beneficial owners of such Investor) to comply with the Sanction Regulations. If the Manager or its designee determines that an Investor or a person holding a beneficial interest in an Investor is subject to any of the Sanction Regulations. the Manager may be obligated by law to block and retain an Investor's investment. Confidential Private Placement Memorandum 101 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0100707 CONFIDENTIAL SDNY GM_00246891 EFTA01394672