Anti-Money Laundering (AML) Policy

Purpose

Gambrell Harvest Fund ("GHF") is committed to conducting its business in a lawful, ethical, and transparent manner. This Anti-Money Laundering ("AML") Policy establishes procedures designed to reduce the risk that GHF's business, services, or infrastructure are used for money laundering, terrorist financing, fraud, sanctions evasion, or other illicit financial activity.

GHF is a proprietary quantitative trading organization focused on algorithmic trading across digital asset exchanges. GHF does not operate as a public cryptocurrency exchange, money transmitter, or custodial wallet provider.

Business Model

GHF develops and operates proprietary quantitative trading strategies utilizing automated execution technologies. Capital is introduced through approved investment partners and traded on regulated digital asset exchanges that maintain their own customer onboarding and Know Your Customer (KYC) procedures.

Customer Acceptance

GHF reserves the right to accept or decline any business relationship at its sole discretion.

GHF may refuse service where:

• The identity of a customer or business partner cannot be reasonably verified.
• The source of funds cannot be reasonably explained.
• The relationship presents elevated legal, financial, or reputational risk.
• The activity appears inconsistent with the stated purpose of the relationship.

Identity Verification

Where applicable, GHF relies upon the customer identification procedures of approved exchanges and investment partners. GHF may request additional documentation whenever necessary to establish ownership, authority, or legitimacy.

Source of Funds

GHF expects all trading capital to originate from lawful sources.

GHF may decline, suspend, or terminate relationships involving suspected:

• Money laundering
• Fraud
• Sanctions violations
• Terrorist financing
• Theft or misappropriation of digital assets
• Other unlawful financial activity

Transaction Monitoring

GHF monitors account activity for behavior that may warrant additional review. Examples include:

• Unusual funding activity
• Unexpected changes in transaction patterns
• Abnormal trading behavior
• Activity inconsistent with the customer's stated purpose
• Requests that appear intended to obscure ownership or source of funds

Where appropriate, GHF may request clarification before continuing services.

Sanctions Compliance

GHF seeks to avoid conducting business with individuals or entities subject to applicable sanctions imposed by relevant governmental authorities, including those of the United States, United Nations, European Union, United Kingdom, or other applicable jurisdictions.

Record Retention

Business records, onboarding documentation, trading records, and other operational information are retained for an appropriate period consistent with applicable legal requirements and sound business practices.

Cooperation with Authorities

GHF will cooperate with lawful requests from regulatory agencies and law enforcement authorities, consistent with applicable laws and contractual obligations.

Policy Review

This policy will be reviewed periodically and updated as necessary to reflect changes in applicable law, industry standards, or the operations of Gambrell Harvest Fund.

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