Anti-Financial Crime Compliance
Program Statement

It is the policy of HLM Acquisitions, LLC (HLMA) to prohibit and prevent money laundering, terrorist financing, sanctions circumvention, and other finance-related criminal activities. HLMA executes this by complying with all applicable regulatory requirements including, but not limited to, the Bank Secrecy Act and OFAC regulations. Further, we remain committed to a quarterly review of our compliance program to account for any material change in our business and/or regulations. ​

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PROGRAM DATE: JANUARY 01, 2026

LATEST REVIEW EFFECTIVE: JULY 01, 2026