Regulatory Notices

Regulatory Status

Aurum Asset Management LLC is not registered as an investment adviser with the U.S. Securities and Exchange Commission (SEC) or any state securities regulator and does not provide individualized investment advice. Aurum is not a broker-dealer and is not registered with the SEC or the Financial Industry Regulatory Authority (FINRA); it does not solicit investors, negotiate the terms of any investment or receive compensation based on capital raised. Any securities offering is distributed exclusively by a registered broker-dealer. Across all of its services, Aurum adheres to best practices of governance, compliance and transparency.

Anti-Money Laundering & KYC

Aurum Asset Management LLC is committed to maintaining robust Anti-Money Laundering (AML) and Know Your Customer (KYC) procedures to prevent illicit financial activities, in compliance with the U.S. Bank Secrecy Act (BSA), USA PATRIOT Act, OFAC regulations, and international AML standards (FATF).

• Collection and verification of government-issued identification.
• Verification of beneficial ownership and source of funds.
• Screening against sanctions and politically exposed persons (PEPs).
• Continuous monitoring of transactions for unusual activity, with periodic reviews and risk assessments of clients.
• Suspicious activities are promptly reported to the appropriate authorities in compliance with U.S. regulations (SAR filings, if applicable).
• Employees receive periodic AML/KYC training. The Compliance Officer ensures enforcement and documentation.

Conflicts of Interest

Aurum Asset Management LLC recognizes that potential conflicts of interest may arise in the course of its activities. Aurum is committed to identifying, disclosing, and managing such conflicts in the best interest of its clients and investors.

Conflicts may arise from the allocation of investment opportunities among clients, relationships with affiliates or service providers, and employees’ personal investments. All material conflicts of interest will be disclosed to clients in writing, prior to or at the time of engagement.

• Segregation of duties and oversight by Compliance.
• Pre-clearance of personal securities transactions by employees.
• Ongoing monitoring and compliance reviews.
• Violations of this policy may result in disciplinary action, up to and including termination.

Code of Ethics

Aurum Asset Management LLC is committed to conducting business with integrity, professionalism, and transparency. Our Code of Ethics establishes the guiding principles for directors, officers, employees, and representatives.

• Integrity and fair dealing. We act honestly and fairly in all relationships with clients, investors, partners, and regulators.
• Compliance with laws. We comply with all applicable laws, including U.S. federal, state, and international regulations.
• Confidentiality. We safeguard all non-public information received from clients and partners.
• Conflicts of interest. We identify, disclose, and manage potential conflicts of interest in an appropriate manner.
• Insider trading. Employees and affiliates are strictly prohibited from misusing material non-public information.
• Professional conduct. We uphold the highest standards of ethical behavior, treating all stakeholders with dignity and respect.
• Accountability. Violations of this Code may result in disciplinary action, including termination of employment or contracts.

Cybersecurity

Aurum Asset Management LLC recognizes the critical importance of safeguarding digital assets, client data, and proprietary information, maintaining operational resilience, and complying with applicable data security laws.

• Firewalls, encryption, and intrusion detection systems.
• Multi-factor authentication for internal systems.
• Secure cloud storage with continuous monitoring.
• Regular software patching and vulnerability assessments.
• Immediate containment and assessment of incidents, with notification to affected parties where legally required.
• Periodic cybersecurity awareness training for all employees.

Business Continuity & Disaster Recovery

Aurum is committed to maintaining the continuity of its operations and ensuring the protection of client interests in the event of a significant disruption, including natural disasters, power outages, IT system failures, cybersecurity breaches, data loss, and pandemic or public health emergencies.

• Secure cloud-based data storage with redundancy.
• Remote work capabilities for all key employees.
• Communication protocols with clients and regulators.
• The plan is tested periodically and updated annually to reflect business and regulatory changes.

Contact

For questions regarding these notices, please contact compliance@aurumasset.us.