• Full Name
• Telephone number
• Email address
• Residential and permanent (if different) address proof e.g. copies of utility bill or bank statement issued within the last three months
• Copy of Passport (Info page) or copy of ID (front and back)
• Date of birth
• Nationality
• Personal photograph (with passport or ID in Hand)
• Information on occupation and a description of Source of Funds for investment
• Tax identification number

• Company Profile
• Certificate of incorporation or equivalent (and certificate on change of company name if applicable)
• Memorandum and article of association
• Company search report issued within the last six months
• Tax identification number
• Signed board resolution authorizing the investment and conferring authority on those giving instructions
• Authorized signature list with specimen signatures
• Valid passport copy of authorized signatory

ACG shall not accept subscribers (individuals or entities) who are not at least eighteen (18) years of age or subscribers from the following jurisdictions (the “Prohibited Subscribers”):

• United States - Individuals or entities from or residing in the United States, including American Samoa, Guam, Northern Mariana Islands, Puerto Rico, U.S. Virgin Islands, or any entity organized or incorporated under the laws of the United States. U.S. citizens living abroad may also be deemed "U.S. Persons" under certain rules.
• Individuals or entities from or residing in high risk countries listed on UNSCR Sanctions List.

• ACG shall screen each prospective subscriber in its fund sale for matches in the following categories:
• Global Sanctions List - Screening prospective subscribers against the UNSCR Sanctions List.
• PEPs - Screening prospective subscribers for identification as a "politically exposed person" with filters such as Thomson Reuters World-Check and/or Comply Advantage. PEP is a term describing someone who has been entrusted with a prominent public function. PEP generally presents a higher risk for potential involvement in bribery and corruption by virtue of their position and the influence that they could hold.
• Adverse Media - Screening prospective subscribers against adverse media involves looking for any negative mentions of them in traditional news media and publicly available information more broadly. Any prospective subscriber that has a match on any of the above categories shall be flagged and blocked pending review by ACG and its Compliance Officer of the red flag. The prospective subscriber will receive an email letting them know of that it is under review and a follow-up email letting the prospective subscriber of the disposition of the review.
  
  Even after KYC approval, ACG may periodically or at least twice in a year, conduct additional or repeat screenings on existing clients, especially when there are changes in client’s information or suspected unusual activities and during the process, ACG have absolute right to request for further supporting documents form its clients. Any suspicious transactions and/or investment detected is subject to immediate Suspicious Transaction Reporting (STR).

• Global Sanctions List - If the flag is a match on the Global Sanctions List, ACG shall deny the subscriber and let them know of the disposition of the review.
• PEPs - If the flag is a match on PEPs, ACG’s Compliance Officer shall review the AML report and may request proof of identification or additional verification from the prospective subscriber
• After receiving any additional verification information, ACG shall provide the prospective subscriber with notice of disposition.
• Adverse Media - If the flag is a match on Adverse Media, ACG’s Compliance Officer shall review the adverse media and make a determination on whether to allow the prospective subscriber.

• ACG is in the process of designating a Compliance Officer to be its Anti-Money Laundering Program Compliance Person (AML Compliance Person), with full responsibility for ACG’s AML program. The duties of the AML Compliance Officer will include monitoring ACG’s compliance with AML obligations, overseeing communication and training for employees.
• The AML Compliance Officer will also ensure that ACG keeps and maintains all of the required AML records and will ensure that suspicious activity reports are filed. The AML Compliance Officer is vested with full responsibility and authority to enforce ACG’s AML program

The Internal Auditor shall objectively review ACG’s business processes, evaluate the efficacy of risk management procedures of ACG that are currently in place and to protect against fraud and theft of the firm’s assets.

In addition, the Internal Auditor shall ensure that ACG is complying with such laws, rules and regulations, including without limitation Section 405 of Hong Kong Companies Ordinance (Cap. 622) and Securities and Futures Ordinance (cap. 571) of Hong Kong (“SFO”) and make recommendations on how to improve internal controls and governance processes.

The Compliance Officer (CO) shall Implement and manage an effective legal compliance program for ACG, develop and review company policies, including KYC, AML and CFT policy and advise the management on the company’s compliance with laws and regulations through detailed reports. The CO shall also create and manage effective action plans in response to audit discoveries and compliance violations, regularly audit company procedures, practices, and documents to identify possible weaknesses or risk, assess company operations to determine compliance risk. The CO shall ensure all employees are educated on the latest regulations and processes and resolve employee concerns about legal compliance.

The External Auditors shall inspect ACG’s accounting records and express an opinion as to whether financial statements are presented fairly in accordance with the applicable accounting standards of the entity, such as International Financial Reporting Standards (IFRS). The External Auditor must assert whether financial statements are free of material misstatement, whether due to error or fraud. The resulting audited financial statements are then examined by a variety of external users, including investors, creditors and government bodies. In addition to performing audits, the External Auditors may provide various tax and consulting services ACG.