Anti-Money Laundering Update

The operators of Cayman Islands' investment funds that are

regulated by the Cayman Islands Monetary Authority

("CIMA") should note that recent changes to the Guidance

Notes on the Prevention and Detection of Money Laundering and

Terrorist Financing in the Cayman Islands (the "Guidance

Notes") issued by CIMA mean that regulated funds are now

required to appoint a Compliance Officer as well as a Money

Laundering Reporting Officer (who can be the same person), at the

management level, who:

has sufficient skills and experience;

reports directly to the governing body of the fund (the

"Operator");

has sufficient seniority and authority so that the Operator of

the fund reacts to and acts upon any recommendations made;

has regular contact with the Operator of the fund so that the

Operator is able to satisfy itself that statutory obligations are

being met and that sufficiently robust measures are being taken to

protect itself against the risk of money...