Opus Investment Management

Legal

Anti-Money Laundering (AML) Policy Summary

Summary of Opus commitment to AML and counter-terrorist financing controls in connection with client onboarding and ongoing monitoring.

Policy commitment

Opus maintains AML policies and procedures designed to detect and prevent money laundering and terrorist financing in accordance with applicable U.S. law. [Counsel review: cite BSA/FinCEN obligations as applicable to RIA activities.]

Customer due diligence

Clients may be required to provide identity verification, beneficial ownership information, and source-of-funds documentation as part of onboarding and periodic reviews.

Monitoring and escalation

Opus may monitor account activity and escalate unusual or suspicious activity to compliance for review and, where required, regulatory reporting. [Counsel review: SAR confidentiality language.]

Cooperation

Clients are expected to cooperate promptly with information requests. Failure to provide required information may result in delayed onboarding, restricted services, or account termination.

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