(1) The document outlines an anti-money laundering policy and client questionnaire for Altos Escondidos, SA. It details requirements for verifying client identity, monitoring transactions, and reporting suspicious activity in accordance with anti-money laundering laws and regulations. (2) Officers must use documentary and non-documentary methods to verify client identity and understand the source of funds. They must monitor for suspicious transactions like unusual secrecy, unexplained transfers between unaffiliated parties, and activity inconsistent with the client's profile. (3) Any potential money laundering or terrorist activity must be reported to senior management and regulators. Thorough record keeping of client information and due diligence is also required to facilitate law

1. Anti-Money Laundering (AML) Policy Statement and Client Questionnaire:
The International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 ("Title III"),
which was signed into law on October 26, 2001, imposed significant new anti-money laundering
requirements on all "financial institutions," as so defined under the Bank Secrecy Act (BSA).
The purpose of this directive is to highlight those minimum standards that the Board of Directors for
Altos Escondidos may require certain Officers to follow.
Due to the nature of our entity structure which is not a money services financial institution, transactions
are limited to deposits for investment purposes and redemptions of those funds. Suspicious transactions
are generally those that have no corresponding bank account verification for the customer, or lack any
reasonable explanation. Identifying suspicious activity may prove difficult and often requires subjective
evaluation because the activity may be consistent with lawful transactions.
Our written Anti-Money Laundering and Anti-Terrorist Financing program, approved by senior
management, is designed to achieve and monitor compliance with the applicable requirements of the
Bank Secrecy Act (31 U.S.C. 5311, et. seq.), and the implementing regulations promulgated there under
by the Department of the Treasury and, as applicable, the Commodity Futures Trading Commission and
Securities and Exchange Commission.
Money laundering occurs when funds from an unlawful activity are moved through the financial
system in such a way as to make it appear that the funds have come from legitimate sources. Money
laundering usually follows three stages. First, cash or cash equivalents are placed into the financial
system. Second, the money is transferred or moved to other accounts through a series of financial
transactions designed to obscure the origin of the money. Finally, the funds are reintroduced into the
economy so that the funds appear to have come from legitimate sources. Officers need to be aware of
potential money laundering abuses that could occur from a client account and report potentially
suspicious activity.
The Board of Directors is committed to following all applicable laws and regulations to ensure that our
business is not used to facilitate money laundering or terrorist financing. Officers of the firm have a
responsibility to ensure compliance with our written anti-money laundering procedures and controls
(Client Questionnaire), and to abide by all applicable laws and regulations involving anti-money
laundering programs.
The Client Questionnaire enables Officers to form a reasonable belief that they know the true identity
of each customer; recognize suspicious transactions; allowing them to report suspicious or unusual
activity to appropriate supervisory personnel, including senior management when appropriate.
Identifying potentially high-risk accounts should occur in the account opening process. Although
attempts to launder money or finance terrorism can come from numerous sources, Officers should be
aware that certain types of entities or individuals from certain geographic locations may pose a greater
risk. Officers should consult the Financial Action Task Force's (FATF) list of non-cooperative countries
and territories (NCCT list) to determine whether a client is from one of those countries or territories.
If the client is from one of the countries/territories identified on the NCCT list, the Officer should
determine what, if any additional due diligence is necessary in deciding whether to open the account,
and if the account is accepted, what if any additional monitoring of the account activity is appropriate.

2. Officers must use risk-based procedures to verify the identity of each client to the extent reasonable and
practicable. Accounts must be verified using a reasonable combination of documentary and nondocumentary methods. The documents that will be used for documentary verification are contained in
the Client Questionnaire.
Documents that would be appropriate for verification include, for an individual, an unexpired
government-issued identification that evidences nationality or residence and bears a photograph or
similar safeguard (e. g. driver's license or passport); and for a non-individual (e.g. corporation,
partnership or trust), documents that show the existence of the entity, such as certified articles of
incorporation, a government issued business license, a partnership agreement or a trust instrument. In
most instances, once an Officer verifies the identity of a client through documentary evidence, the
Officer does not have to determine whether the document is valid. However, if the document shows an
obvious indication of fraud, then Officer must report to senior management to determine whether the
document is sufficient for the firm to form a reasonable belief that it knows the customer's true identity.
Appropriate non-documentary methods include contacting a customer; independently verifying the
customer's identity through the comparison of information provided by the customer with information
obtained from a consumer reporting agency, public database or other source; checking references with
other financial institutions; or obtaining a financial statement. An Officer may also want to examine
whether there is a logical consistency between the customer's name, street address, ZIP code, telephone
number, date of birth and social security number.
For purposes of our client reporting requirements, a client includes individuals or entities opening new
accounts. Requirements for certain intermediated accounts, where the intermediary is the account
holder, should focus on the intermediary, not the underlying participant or beneficiary. For example, in
the case of an omnibus account, an Officer should treat the intermediary as the customer and does not
have to apply the Client Questionnaire requirements to the underlying beneficiaries. Similarly, if an
intermediary opens an account in the name of a collective investment vehicle such as a commodity
pool, the Officer is not required to apply the Client Questionnaire to the pool's underlying participants.
Accounts opened in the name of a corporation, partnership or trust that is created or conducts
substantial business in a jurisdiction that has been designated by Treasury as a primary money
laundering concern or has been designated as non-cooperative by FATF may pose additional risks. If a
client fails to ascertain the client’s identity from both the documentary and non-documentary due
diligence then the Officer may request information, if the client is an entity and not an individual, to
verify a client’s identity.
Officers should take reasonable steps to (1) ascertain the identity of all nominal and beneficial owners
of a private banking account; (2) ascertain whether any owner of the account is a senior foreign
political figure; (3) ascertain the source(s) of funds deposited into a private banking account and the
purpose and expected use of the account; and (4) review the activity of the account to ensure that it is
consistent with the information obtained about the client's source of funds and with the stated purpose
and expected use of the account.
If an Officer intends to reasonably rely on another financial institution to verify the client’s identity, it
must specify how it has done so. Generally, an Officer may rely on another financial institution if: (1)
the reliance is reasonable under the circumstances; (2) the other financial institution is subject to an
AML compliance program requirement under the BSA and is regulated by a Federal functional
regulator; and (3) the other financial institution enters into a contract requiring it to certify annually to

3. the Officer that it has implemented an AML program and that it will perform the specified requirements
of its own compliance program. If the Officer meets these requirements, it will not be held responsible
for the failure of the other financial institution to adequately fulfill the due diligence obligations.
Officers should familiarize themselves with the following red flags for suspicious transactions:
A client exhibits an unusual level of concern for secrecy, particularly with regard to the client's identity,
type of business or source of assets;
A corporate client lacks general knowledge of its own industry;
A client appears to be acting as an agent for another entity or individual but is evasive about the
identity of the other entity or individual (except situations involving the identity of ownership interests
in a collective investment vehicle);
A client is from, or has accounts in a country identified as, a haven for bank secrecy, money laundering
or narcotics production;
A client makes a funds deposit followed by a request that the money be wired out or transferred to a
third party, or to another firm, without any apparent business purpose.
Officers must report to senior management any clients that are on a Terrorist Watch List or if a client
appears on any list of known or suspected terrorists or terrorist organizations issued by any Federal
government agency and designated as such by Treasury in consultation with the Federal functional
regulators.
Our auditing firm also requires that we maintain an adequate audit trail to assist law enforcement
agencies in any investigation. The key components of these policies, procedures and controls are
discussed below.
At a minimum, records must be kept for seven years for: (1) all identifying information obtained from a
client; (2) either a copy or a description of any document that was relied on to verify identity, noting the
type of document, any identification number contained in the document, the place of issuance, and if
any, the date of issuance and expiration date; (3) a description of the non-documentary verification
methods or additional verification methods used and the results; and (4) a description of the resolution
of each substantive discrepancy discovered when verifying the identifying information obtained.
Officers should understand that AML and Terrorist Financing is an evolving area and the Board of
Directors expects to provide further guidance as additional requirements in this area are imposed.
Your compliance is greatly appreciated.
Best regards,
Athisayaraj Mahadevan
Managing Partner
Altos Escondidos, SA

4. CLIENT QUESTIONNAIRE (CONFIDENTIAL)
You are being asked to answer the questions which follow in connection with your subscription to
purchase Membership Units issued by Altos Escondidos, SA, a company formed under the laws of the
Republic of Panama (the “Company”).
The Membership Units are being offered to a limited number of qualified investors without registration
under the Securities Act of 1933, as amended (the “Securities Act”), in reliance on the private offering
exemption contained in Section 4(2) of the Securities Act and Regulation D and Rule 147 promulgated
thereunder. The availability of the exemption depends, in part, on a determination that each purchaser
qualifies as an “accredited investor,” as defined in Rule 501(a) under the Securities Act.
The information supplied will be used in determining whether proposed purchasers of Membership
Units meet such criteria. The information will be kept confidential and will not be disclosed except to
the Managing Members of the Company, its counsel, the Company’s selling agent in the offering of the
Membership Units and its counsel, and, if required, to governmental and regulatory authorities.
I (we) understand the Membership Units are being issued without registration under the Securities Act
in reliance upon the private offering exemption contained in Section 4(2) of the Securities Act and
Regulation D promulgated there under or excluded from the Federal registration requirement pursuant
to Regulation S for offers and sales of securities outside the United Sates of America, and that such
reliance is based in part on the information herein supplied. For the foregoing reasons, and to induce
the Company to accept my subscription for Membership Units, I represent and warrant that the
information stated herein is true, accurate and complete to the best of my knowledge and belief, and I
agree to notify and supply corrective information promptly if, prior to the consummation of my
purchase of Membership Units, any of such information becomes inaccurate or incomplete.
THE UNDERSIGNED HEREBY GIVES EXPRESS WRITTEN CONSENT TO THE COMPANY
AND THE CO-MANAGING MEMBERS TO REQUEST ADDITIONAL INFORMATION, OBTAIN
CONSUMER REPORTS ON THE UNDERSIGNED OR THE UNDERSIGNED’S BUSINESS, AND
TO CONTACT THE BANKS AND PROVIDERS OF SERVICES LISTED IN THIS INVESTMENT
QUESTIONNAIRE TO VERIFY AND/OR CLARIFY THE INFORMATION CONTAINED HEREIN.

5. 1.
Documentary Evidence:
Please provide an unexpired government-issued identification that evidences nationality or residence
and bears a photograph or similar safeguard (e. g. driver's license or passport); and for a non-individual
(e.g. corporation, partnership or trust), documents that show the existence of the entity, such as certified
articles of incorporation, a government issued business license, a partnership agreement or a trust
instrument.
Total Amount of Investment: $ ____________________
Source of Funds:
_______________________(Stock sale, equity line, etc.)
Purpose of Investment
:
_______________________(Portfolio diversification, etc.)
2.
(a)
(b)
(or)
(or)
(c)
Personal
Full Name:
Social Security No.:
Passport/ID No.:
Tax ID No.:
Residence Address:
City, State, Zip:
(d)
Telephone Number (Area Code): (______) __________________
(e)
Age:
(f)
Are you (Check one):
(g)
Do you file jointly?
(h)
Are you a citizen or permanent resident of the United States?
____Yes
____ No
3.
Employment
(a)
(b)
(c)
Employer:
_________________________________________
Business Address:______________________________________
City, State, Zip:
___________________________________
Business Telephone Number (Area Code): (______) ___________
(d)
Nature of business: ____________________________________
(e)
Position: ____________________________________________
(f)
Length of Time in Present Position: _______________________
(g)
Other business-related activities (service on boards of directors, etc.)
_____________________________________________________
_____________________________________________________
___________________________________
___________________________________
___________________________________
___________________________________
___________________________________
___________________________________
_____
____ Married
____Yes
____ Single
____ No

6. 4.
Send correspondence to:
Home ____
Office ____ Other ____:
5.
What is your net worth exclusive of your home, car and furnishings?
____________________________________________________________
____________________________________________________________
6.
What are the sources of your wealth?
____________________________________________________________
____________________________________________________________
7.
Investment Experience
Describe briefly your prior investment experience in both marketable and unmarketable
securities. If none, please so state.
____________________________________________________________
____________________________________________________________
____________________________________________________________
____________________________________________________________
8.
Other Experience
Describe any other substantial experience you have in accounting or financial matters including
your educational background (schools attended and degrees obtained):
____________________________________________________________
____________________________________________________________
____________________________________________________________
____________________________________________________________
____________________________________________________________
____________________________________________________________
9.
Investment Advice
(a)
In connection with your proposed purchase of Membership Units, will you seek advice from
any lawyer, accountant, investment advisor or other person or persons? Yes ____
No
____
If yes, please set forth the name, profession or occupation and business of each prospective
advisor and, if more than one, explain briefly the division of responsibilities between them:
____________________________________________________________
____________________________________________________________
____________________________________________________________
(b)
What qualifies each such person to evaluate the merits and risks of this investment and to act as
your advisor (education, past experience, professional competence, time in profession,
accounting certificates, SEC registration, etc.), and how long have you dealt with such person or
persons professionally?
____________________________________________________________
____________________________________________________________
____________________________________________________________
____________________________________________________________

7. 10.
REPRESENTATIONS AND WARRANTIES
I understand that the Company will be relying on the accuracy and completeness of my responses to the
foregoing questions. I represent and warrant to the Company as follows: (i) the answers to the above
questions are complete and correct and may be relied upon by the Company in determining whether the
offering of Membership Units are exempt from registration under the Securities Act, and (ii) I will
notify the Company immediately of any material change in any statement made herein occurring prior
to the closing of any purchase by me of Membership Units. I will also provide upon request of the
Company a copy of a personal financial statement reflecting my assets, liabilities, and net worth or
recent tax return to reflect my income.
IN WITNESS WHEREOF,
I have executed this Client Questionnaire
this _____ day of ______________, 2014.
___________________________
(Signature of Subscriber)
___________________________
(Signature of Spouse, or other joint tenant, if any)
___________________________
(Printed Name of Subscriber)
___________________________
(Printed Name of Spouse, or other joint tenant)
OR
___________________________
(Name of Entity)
By: ___________________________
(Signature)
___________________________
(Print Name)
___________________________
(Title)