Neuberger Berman BD LLC
Anti-Money Laundering Public Statement

Neuberger Berman BD LLC (“Neuberger Berman”) is a member of FINRA and SIPC and is regulated by the United States Securities and Exchange Commission and Financial Industry Regulatory Authority. Neuberger Berman is fully committed to complying with applicable statutory and regulatory requirements designed to combat money laundering and any activity which facilitates the funding of terrorist or criminal activities, including but not limited to the USA PATRIOT Act. We hereby confirm that we have policies and procedures in place designated to comply with all applicable anti-money laundering legislation and regulations in our jurisdiction including the Bank Secrecy Act and USA PATRIOT Act.

Some of the initiatives and procedures undertaken by Neuberger Berman include:

  • the establishment of a comprehensive money laundering prevention compliance program approved by Senior Management;
  • the development and utilization of technology to assist in the monitoring of transactions for the purpose of identifying and reporting suspicious activity and/or transactions;
  • know your customer (KYC) standards including customer identification and verification procedures;
  • due diligence and enhanced due diligence procedures for foreign politically exposed persons, foreign banks and other high risk customers;
  • compliance with the prohibition from doing business with, or on behalf of shell banks;
  • the designation of a money laundering prevention compliance officer to oversee the money laundering prevention efforts of Neuberger Berman;
  • procedures for screening clients against applicable sanction programs and lists including but not limited to those issued by the U.S. Department of Treasury’s Office of Foreign Assets Control;
  • the establishment of an independent audit function to annually evaluate Neuberger Berman’s money laundering prevention program; and
  • the training of and certification by employees.

In addition, Neuberger Berman has established and maintains a Customer Identification Program which includes procedures to:

  • verify the identity of any person seeking to open an account, to the extent reasonable and practicable;
  • determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to broker dealers by any government agency;
  • provide notice to customers that information may be requested in the process of verifying their identities; and
  • maintain records of all information obtained to verify a customer’s identity, as is required by law.