ACAMS Code of Conduct - Updated 3/28/2024

Introduction and Purpose
Association of Certified Anti-Money Laundering Specialists LLC (together with its subsidiaries andaffiliates, collectively, “ACAMS” or the “Company”) serves as a world leading membership organization
for Anti-Financial Crime professionals. It aims to support the individuals and organizations that it serves
as well as the communities in which it operates. Thus, all of the activities of ACAMS shall be performed
with integrity, candor, and with a focus on supporting the interests of the Company’s employees,
customers, and the communities in which it operates.
ACAMS has adopted this Code of Business Ethics and Conduct (this “Code”) to support these principles
and to accomplish its objectives. This Code includes provisions based on existing law and standard
requirements, as well as more specific provisions and principles based on the nature of ACAMS’ businessand the requirements of the contracts it is bound by. Each employee of the Company is expected to readand abide by the terms of this Code, and to notify their manager, the Chief Human Resources Officer orVice President of Legal of any non-compliance.
This Code shall apply to the Company and its employees. It also shall flow down to and apply to its
subcontractors. This Code also shall flow-down to independent contractors in their capacity of working
on behalf of ACAMS. The GC/CCO/other position, involving as necessary legal counsel, shall be
responsible for implementation and Compliance with this Code. Violations of this Code are cause forappropriate corrective action, including discipline up to and including termination of employment.
The Company is committed to fostering an environment where integrity, honesty and good citizenship isvalued and is used as the driving force behind all decisions. The Company provides that this Code ismade accessible to all those subject to its provisions. The Company will maintain a culture thatencourages all employees and subcontractors to become familiar with this Code and to feel comfortableand encouraged to report any suspected violations of it to their manager, the Chief Human Resources
Officer or Vice President of Legal.

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ACAMS Code of Conduct

Message from ACAMS CEO
Dear Colleagues,

As an organization that is mission-driven and that deeply prides itself on our core values of Purpose,
Integrity and Partnership, living by our values enables us to make a profound impact within our global
communities each and every day.
In an effort to equip you with the right resources to do so, we have implemented a Code of Conduct toprovide clear guidelines on our standards of professional behaviors and to empower you in your day-today decision making that upholds our core values.
Your understanding, support and compliance with our code of conduct enables ACAMS to lead with thehighest levels of integrity and best serve our customers, members, partners and each other at all times.
If you have any questions, please contact ethics@acams.org.
Thank you for your steadfast support and for making ACAMS the dynamic mission-driven organization it
is.

Best,
Neil

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ACAMS Code of Conduct

About Our Code of Conduct
Compliance with laws, rules and regulations, Company policy, and with this Code. ACAMS and its
employees shall follow both the letter and the spirit of laws and regulations that govern the Company.
This includes compliance with the laws, rules, and regulations of each of the jurisdiction in which theCompany operates (except to the extent inconsistent with U.S. Law). Should any issue arise, employees
should seek advice from the Vice President of Legal or their designee. Moreover, the provisions of the
Handbook also inform the Company’s policies and procedures. Several policies within this Code aredescribed in further detail in the Company Handbook.
Amendments. Amendments to this Code require the written approval of the Vice President of Legal.
Employee and contractor responsibilities. Employees and contractors have the responsibility to ask
questions, seek guidance, report suspected violations, and express concerns regarding compliance withthis Code and all related policies and procedures. Employees of the Company are considered to bepersons employed by ACAMS, in part or full time capacity. While consultants and subcontractors
performing services for ACAMS are not employees of ACAMS, they are obligated when performing workfor the Company to follow these policies as described within this Code. A subcontractor under this Codefollows the definition of U.S. Federal Acquisition Regulations (“FAR”) 3.502-1 of “any person, other thanthe prime contractor, who offers to furnish or furnishes any supplies, materials, equipment, or servicesof any kind under a prime contract or a subcontract entered into in connection with such prime
contract; and… any person who offers to furnish or furnishes general supplies to the prime contractor ora higher tier subcontractor.” This Code is applicable to persons who work in any capacity for ACAMS,
whether or not they are considered to be a government contractor. A few helpful examples andreminders can be found at the end of this Code of Conduct.
Management responsibilities. Managers shall promote the Company values and standards of conductboth in letter and spirit of laws, as summarized in the Code and regulated by the Company.
Management shall lead by example and model the highest standards of ethical business conduct andcompany values. This includes knowledge of such so that management can efficiently and effectively
assist the Company and its employees in resolving questions and concerns. Management shall also
create an environment that encourages open communication and reporting regarding ethics, businessconduct, and legal issues. Management shall report any such information regarding potential violationsof this Code in a timely manner to the Vice President of Legal or their designee.

Compliance Program and Reporting Compliance Violations.
Ethics and Business Conduct Program. ACAMS shall maintain a comprehensive Compliance Program toensure continued compliance with applicable Federal and State laws and regulations, including those
provided in this Code. This Compliance Program shall be modeled off of the Federal Sentencing
Guidelines, Department of Justice Evaluation of Corporate Compliance Programs, and other published3

ACAMS Code of Conduct

guidance for establishing and maintaining an effective Compliance Program. All employees, as defined
above, are expected to be familiar with and comply with the Company’s policies, procedures, and thisCode. The Company shall establish criteria for ethics education and awareness in accordance with theCompany’s culture of open communication and integrity. The Company shall respond to employeequestions about ethical conduct and compliance and encourage such inquiries.
Training of Employees. All employees are to participate in a formal ethics training session as soon aspracticable after joining the Company and at least annually thereafter. This applies to all Company
employees unless expressly exempted by the Vice President of Legal in writing. Employees are also toreceive privacy training in accordance with FAR 52.224-3. To the extent applicable, this training shall be
conducted as soon as practicable upon an employee’s hire and again annually thereafter.
Obligations to Report Violations of this Code. FAR 52.203-13 (under 73 Fed. Reg. 67064) requires
government contractors, such as ACAMS, to disclose to the Inspector General of the relevant
government agency holding its contract any credible evidence of violation of federal criminal laws inviolation of Title 18 or the civil False Claims Act. Note that additional laws and policies may apply locally.
In such case, please refer to such local law or policy. In order for the Company to accurately makedisclosures, it is essential that employees report all violations or suspected violations of the Code,applicable law, or a contract provision, to the Vice President of Legal. Failure to report may itself be a
violation of this Code or applicable law.
Reports may be made to the Vice President of Legal or their designee directly at ethics@acams.org oranonymously through a hotline. Whether contacting the Vice President of Legal or their designee orusing the Company Compliance Hotline, an employee need not provide his or her name. If a name isprovided, it will not be disclosed without the permission of the employee except as needed to conduct
an investigation, implement corrective action, or notify law enforcement authorities.
In addition to reporting violations, employees are encouraged to contact the Vice President of Legal or
their designee to discuss any ethics concerns or questions about this Code.
To report a violation, employees shall use any of the below methods:••

Phone: +1 410 209 0102
Email: ethics@acams.org

In addition, an employee may report violations of this Code or applicable law to the Company
Compliance Hotline by the following methods:·

Website: https://www.lighthouse-services.com/acams·

Anonymous Reporting App: Keyword: acamso Detailed app instructions download here

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ACAMS Code of Conduct·

Toll-Free Telephone:o English-speaking USA and Canada: 833-203-6447
o Spanish-speaking USA and Canada: 800-216-1288
o Spanish-speaking Mexico: 01-800-681-5340
o French-speaking Canada: 855-725-0002·
E-mail: reports@lighthouse-services.com (please be sure to include “ACAMS” in thesubject line and body of your report)·

Fax: 215-689-3885 (must include company name with report)*Should you need international dialing instructions, please refer to the instructions found athttps://www.acams.org/codeofconductinternationaldial
No Retaliation. Employees who report a violation or suspected violation of this Code or applicable law
are not subject to penalty so long as such report was reasonable and made in good faith. The Company
will not tolerate retaliation against anyone who makes a reasonable, good faith report, even if thereport is ultimately mistaken. The Company will similarly not tolerate retaliation against anyone who, ingood faith, participates in an investigation or reports misconduct. An employee who makes a report will
not be fired, demoted, suspended, threatened, or subject to any adverse treatment in the course of
employment because of any report, including reports made to the government.
Ethics Process and responding to investigations. The Company shall provide, where practicable,
confidential assistance to employees making reports. The Company commits to reviewing andinvestigating each report in a timely manner. Appropriate management will be involved as necessary. All
documents and communications related to reports shall be maintained in compliance with applicablelaws regarding document conservation and protection of personal data. If applicable law does not
specify a maintenance period, the maintenance period shall be 3 years. Measures shall be taken to
maintain confidentiality and protect anonymity.

Relations with Third Parties
Business activities and relations with customers and suppliers. All communications andrepresentations to prospective customers, suppliers, and partners shall be accurate and truthful.
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Business partners are expected to follow the spirit of this Code, as well as any applicable contractual
provisions, when working on behalf of the Company.
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Supplier diversity. The Company recognizes the importance and benefits of a diverse supplierbase, and will work to identify qualified minority-owned and woman-owned businesses, as wellas small and local businesses capable of providing ACAMS with products and services.
Hiring or Contracting with Ineligible or Excluded Individuals or Entities. The Company shallconduct appropriate due diligence before engaging any third-party that will be marketing or
utilizing Company products and services outside of the United States.

Political contributions and involvement. The Company does not support political parties or engage inprohibited lobbying activities. Employees have a right to voluntarily participate in the political process,and such individual actions shall be done in the employees own name and on their own time—remaining separate from Company activities. Employees shall consult with the Legal department before
interacting with government officials in a manner that might be interpreted as a lobbying activity.
Employees shall also be careful to ensure that their personal political views, contributions, and activities
are not viewed as those of the company.
Correspondence with the public. Only authorized persons may speak on behalf of the Company. The
Company shall provide accurate and consistent information regarding operations, products, and services
to the public. Employees shall obtain approval from the Communications department before making
public statements when being identified as an employee of ACAMS. Employees shall be careful to avoid
the appearance that they are speaking on behalf of the Company in any personal capacity.
Doing business lawfully and ethically outside of the United States. Anything of value (including any gift,
invitation, payment, service or any type advantage), if offered, given, or received in order to obtain an
improper business advantage, may be considered bribes. Company employees must consult with theLegal department prior to offering, giving, or receiving anything of value to Foreign Officials, customers,
suppliers and any third-party with the exception of nominal or de minimis gifts.
Charitable contributions to any Foreign Entities cannot be made by or on behalf of the Company unlessreviewed and approved by the Legal department. Foreign Entities include non-U.S. governmental, semigovernmental or judicial entity or authority, independent or otherwise, including any provincial
government, local-level government, and any statutory or public body established under a law; (ii) any
political party; (iii) any entity or business that is owned or controlled by any of those bodies listed in
subcategory (i) or (ii); or (iv) any international organization, such as the United Nations or the World
Bank. Foreign Officials include (i) any director, officer, employee, agent, or representative (including
anyone elected, nominated, or appointed to be a director, officer, employee, agent, or representative)of any Foreign Entity, or anyone otherwise acting in an official capacity on behalf of a Foreign Entity; (ii)any political party, political party official, or political party employee; (iii) any candidate for public or
political office; (iv) any royal or ruling family member; or (v) any agent or representative of any of those
persons listed in subcategories (i) through (iv).

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Relations with press and mass media. Employees shall not disclose information about the Company, itscustomers, or its employees to the media or any outside entity unless the employee has written
authorization to do so. Any employee who receives a media inquiry shall not engage with the media,
and shall instead pass the information to the Communications department.
Gifts, Gratuities, and Other Business Courtesies. The Company shall ensure that any business courtesy
offered or accepted is permitted by law and policy and will not provide a competitive advantage. The
Company shall also avoid a perception that favorable treatment is being sought, received, or given in
exchange for business courtesies. ACAMS employees shall be aware that complex rules and monetaryrules apply when dealing with government employees. ACAMS employees involved in making purchases
on behalf of the Company shall not solicit any gifts or business courtesies, nor shall they accept gifts
from suppliers of more than nominal value.

Compliance with Laws
Conflicts of Interest. The Company shall remain fair and impartial in all business dealings, including by
avoiding actual conflicts of interest as well as activities that create the appearance of a conflict ofinterest. Employees and those acting on behalf of the Company should avoid situations that might force
choosing between personal interests and the interests of the Company. Employees shall be familiar withwhat is considered a conflict of interest and are tasked with providing written disclosure of actual or
potential conflicts as soon as they become aware of them.
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Examples of Conflicts of Interest. While it is not possible to describe or anticipate all
circumstances amounting to a conflict of interest, such conflicts shall be avoided to the extent
practicable. For instance, conflicts with current and former government employees shall be
avoided, as should organizational conflicts of interest (e.g. conflicts that provide an unfair
competitive advantage or that might impair objectivity). Other examples of conflicts include
familial conflicts, relationships with customers, suppliers, and competitors, and influencing
terms of a future opportunity in which the Company might have an interest in bidding. If theemployee is uncertain about an interest interfering with the employee’s objectivity, they shallcontact the Vice President of Legal or their designee for review and a conflict of interest
determination.

Insider Trading. The Company shall not engage in insider trading. It shall comply with all applicablesecurities laws and provisions, as well as avoid even the appearance of impropriety. The Company andits employees shall not trade, or provide any information or trade advice, on the Company’s securities,
or that of any company it works with or represents. Employees shall not tip another person, including a
relative or another employee, regarding material non-public information that could enable that person
to trade securities. The Company and its employees shall know that any important information learned
during the course of employment may be considered material nonpublic information, and thus shall notdisclose such information to others, even if the employee does not themselves trade any securities
based on the information.
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ACAMS Code of Conduct

Adherence to antitrust laws. The Company shall not knowingly enter into business arrangements thateliminate or discourage competition or provide ACAMS with an improper competitive advantage. Such
activities include, but are not limited to, disparaging a competitor, price fixing, boycotting suppliers or
customers, blocking market entry, colluding with other business to fix prices, and conditioning the saleof a product/service on the sale of another product/service. Employees shall consult with the Vice
President of Legal if they are unsure whether a proposed activity complies with antitrust laws.
Export/import controls and compliance. The Company shall comply with all applicable export andimport laws and regulations. These laws and regulations include both those of the United States andeach foreign country in which the Company conducts business. The Company shall obtain government
approvals prior to exporting and importing products and technology controlled by the Government.
Compliance with Anti-Corruption laws. The Company shall have zero tolerance for bribery andcorruption. The Company shall comply with the laws and regulations of the United States, particularly
the provisions of the Foreign Corrupt Practices Act (“FCPA”), 15. U.S.C. § 78dd-1, et seq., as well as theanti-corruption and anti-bribery laws and regulations of each foreign country in which the Company
operates. The prohibition includes attempts to corrupt, which are illegal acts in themselves.
Compliance with the Anti-Kickback Act/Statute. The Company shall not offer, give, solicit or receive any
form of bribe or kickback, in compliance with the Anti-Kickback Act of 1986 (Title 41, U.S. Code §§ 51–58). The Anti-Kickback Act prohibits requesting, receiving, offering, or paying anything of value, in cash
or in kind, to an employee of a prime U.S. government contractor or higher tier subcontractor in orderto obtain or reward favorable treatment.
Compliance with US anti-boycott laws. The Company shall not participate in or promote boycotts that
the United States does not support. Employees are responsible for reviewing all transactional
documents for any language that may constitute a boycott request.
Compliance with the Service Contract Act. The Company shall comply with all provisions of the Service
Contract Labor Standards, including minimum wages and fringe benefits determined by the Secretary ofLabor or authorized representative, as prescribed at FAR 52.222-41. The Company shall also comply with
Exemptions from Application of the SCA Standards as prescribed in FAR 52.222-51 and FAR 52.222-53.
Trade agreements and restrictions on certain foreign purchases. The Company shall adhere to FAR
52.225-5 and FAR 52.225-13, which define trade agreements and place restrictions on certain foreignpurchases, respectively.
Contracting with the U.S. Government and Truth in Negotiations Act.
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Timekeeping. It is the responsibility of all Company employees who charge time to a U.S.
Government contract to comply with the requirements of the Company’s timekeeping system.
All employees shall be aware of the rules that govern the recording, allocating, and charging ofcosts to the U.S. Government. Employees shall ensure that no improper or false entries are
made to company records and that no improper amounts are charged to U.S. Government

ACAMS Code of Conduct--

contracts. Additional details about employee timekeeping expectations can be found in the
Employee Handbook.
Proposals. Employees involved in the preparation or submission of proposals must ensure thatall proposals are in compliance with applicable cost accounting standards and the FAR costprinciples. Employees shall ensure that all data is current, accurate, and complete as required bylaw. They shall similarly insure that all contractual, regulatory, and statutory requirements arecomplied with, or will be complied with, before contract award.
Subcontractors. The Company shall ensure that all subcontracts are awarded to qualified
subcontractors and that the terms of the prime contract are complied with. The Company mustalso incorporate applicable U.S. Government flow-down provisions into all subcontracts.

Accounts and records
Financial and accounting books and records of the Company / Accounting and Recordkeeping. The
Company shall honestly and accurately prepare all business and financial records in accordance withestablished finance and accounting procedures and applicable laws and regulations. All records shall be
stored in a secure location for the period of time required by law or policy, whichever is longer. Records
that are no longer needed shall be properly disposed of in accordance with applicable document
retention policies. The Company shall make accurate public disclosures. The Company shall not
misrepresent facts or falsify records. If an employee learns of or suspects inaccurate or false records orreporting, or is instructed to make an inaccurate record or report, the employee shall communicate
their concerns to the Vice President of Legal or their designee.
Use of Confidential Information. All employees and those acting on behalf of the Company who haveaccess to confidential information must not misuse, disclose, or disseminate this information to any
individual, including other employees or external parties, without authorization. The Company and its
employees shall obtain proper authorization before disclosing or receiving any sensitive information,
including information about the Company or its customers. Any information provided to employees
during their employment shall remain confidential beyond the course of such employment. Employees
are prohibited from using any Company information or property for personal gain or to compete with
the Company directly or indirectly.
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Prohibition on Requiring Certain Internal Confidentiality Agreements or Statements. The
Company shall comply with FAR 52.203-19. This means that the Company shall “not require its
employees or subcontractors to sign or comply with internal confidentiality agreements orstatements prohibiting or otherwise restricting such employees or subcontractors from lawfully
reporting waste, fraud, or abuse related to the performance of a Government contract to a
designated investigative or law enforcement representative of a Federal department or agency
authorized to receive such information.” The Company shall encourage such reports.

Use of Company Assets and Property. Because the Company is responsible for properly using
customers’ property and assets, neither the Company nor its employees shall waste or abuse Company
9ACAMS Code of Conductand customer assets. This includes a prohibition on unauthorized use of company assets, third party
information, and the handling of sensitive information on a personal device.
Network/Computer Use. Company information technology, including but not limited to email,computers, and mobile devices, shall only be used for authorized, business purposes. Such information
technology may not be used to view, download, or communicate inappropriate, unprofessional,
copyrighted, or illegal content. Personal use of such technology is discouraged and shall not adversely
affect productivity or the work environment. The Company reserves the right to review all information
technology usage. Employees shall report any suspicions of misuse of company assets.
Privacy. All employees who have access to personal information related to employees and otherindividuals are obligated to protect the information and exercise caution before disclosing it to others.
This includes medical information and any other personally identifiable information.
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Contractors Performing Private Security Functions Outside the US. The Company shall adhere
to FAR 52.225-26, which requires, among other things, the registration of military vehicles andpersonnel performing private security functions, as well as the report of incidents involving
personnel performing private security functions.

Workplace Behavior/Human Resources
The Company is committed to maintaining a drug-free, safe, and courteous work environment, freefrom violence, harassment, intimidation, and discrimination. These policies have been fully described in
the ACAMS Employee Handbook, and are briefly summarized here.
Harassment/safety and environment. The Company prohibits verbal or physical conduct that offends,
abuses, intimidates, or threatens another person. This includes sexual harassment conducts by oragainst its employees or third-parties. The Company shall maintain an environment free of physical,
psychological, and verbal harassment or abuse. This includes prohibition on harassment via forms ofelectronic communications and harassment taking place by employees outside the workplace.
Diversity and Non-Discrimination. There is zero tolerance for discrimination. The Company shallmaintain an inclusive and diverse work environment free from discrimination and harassment. The
Company values different ideas, opinions, and experiences and is committed to sustaining a culture that
promotes these values. The Company shall not discriminate against employees on the basis ofcharacteristics protected by applicable law or ACAMS policy. The Company shall follow all policies andlaws, including but not limited to non-discrimination, related to recruitment, selection, compensation,
termination, disciplinary action, and all other aspects of employment. Protected characteristics include,
but are not limited to: Race, ethnicity, religion, sex, age, veteran status, disability, sexual orientation,
gender identity or expression, mental or physical disability, and any other legally protectedcharacteristic.

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Equal opportunity. The Company shall provide equal opportunity to all applicants and employees
regardless of any characteristic protected by law, including but not limited to: Race, religion, sex, age,veteran status, handicap, physical or mental disability, or genetic information. The Company shall follow
a written Affirmative Action Plan (“AAP”), developed in accordance with the provisions of U.S. federallaw, to support and implement the principles of equal employment and to promote the employment
and advancement of persons specifically identified by statute and regulation including minorities,
women, qualified disabled persons and veterans. Management and employees are responsible foractively supporting the Company’s commitment to equal opportunity, and management is responsible
for taking appropriate actions to prevent violations of this policy.
Workplace Violence. The Company prohibits employees from engaging in workplace violence while on
Company property, conducting Company business, attending a Company sponsored event or function,or representing the Company.
Drugs/Alcohol. Employees are prohibited from being under the influence of illegal drugs or alcohol in
the workplace or in the performance of company business. ACAMS shall not knowingly hire or rehire
individuals involved in the possession, use, sale, manufacture, traffic, or transfer of illegal drugs. The
Company shall comply with the Drug-Free Workplace Act of 1988 and other laws and regulations
concerning violations of drugs in the workplace.
Smoking/Tobacco: The use of tobacco products, e-cigarettes, and any other inhalant producing smoke
or vapor is prohibited in Company facilities, during Company-sponsored activities, or in the regularcourse of business. Smoking is only authorized during approved applicable break and meal periods, andafter the normal work schedule. No additional breaks are allowed for employees who smoke.
Human rights/human trafficking. The Company shall recognize and adhere to internationally recognizedhuman rights provisions in all locations where they operate, regardless of local business customs. The
Company is also committed to providing safe and secure conditions for those working on ACAMS’
behalf. The Company will not knowingly work with business partners who employ children or forcedlabor. This includes adherence to FAR 52.222-50, Combatting Trafficking in Persons. Employees are
expected to report any credible information on suspected human rights or human trafficking related
violations to the CO and the agency IG.

Prohibitions on Contracting
Prohibition on Contracting for Hardware, Software, and Services Developed or Provided by Kaspersky
Lab and Other Covered Entities. The Company shall adhere to FAR 52.204-23, including its reporting
requirement. The Company shall insert the substance of FAR 52.204-23 into all subcontracts.
Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services orEquipment. The Company shall adhere to FAR 52.204-25, including its reporting requirement. The
Company shall insert the substance of FAR 52.204-25 into all subcontracts.

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Effects of Violations
Whistleblower Policy. All employees of the Company have an obligation to report their concerns to theCompany as soon as possible if they have any reason to believe that there have been violations of thisCode, contract provisions, or applicable laws. As stated previously in this Code, employees who report a
violation or suspected violation of this Code or applicable law are not subject to penalty so long as suchreport was reasonable and made in good faith. The Company will not tolerate retaliation against anyone
who makes a reasonable, good faith report, even if the report is ultimately mistaken.
Deviations and Exceptions to this Code. Any deviation or exception to this Code requires prior written
approval of the Vice President of Legal. Deviations or exceptions will not be granted if the requests
violate applicable U.S. or foreign law.
Effective Date of Code. This Code is effective November 1, 2022 and applies to conduct occurring (ordisclosure required) on or after November 1, 2022.

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Code of Conduct Examples
ACAMS recognizes that all fact patterns are unique and encourages anyone to whom this Code of
Conduct applies to contact the ACAMS Legal Department with any questions, comments, or concerns
about the Code of Conduct or how it may apply to a certain fact or fact pattern. If you prefer, you may
also use the hotline, or other reporting methods listed in the Code of Conduct.
As a reminder, you should be particularly careful in any instance where a potential improper payment or
improper benefit (e.g., competitive advantage) is even conceivable. You can help reduce risk byconducting proper counterparty diligence and being particularly cautious in any instances involving
payments to governments and government officials.
Below are a few examples of Potentially Risky or Prohibited Behaviors as well as Proper Behaviors.
Potentially Risky or Prohibited Behaviors:
By way of illustration and not limitation, ACAMS, its employees, and third parties when acting on
ACAMS’ behalf shall not:--Enter into a business relationship with a third party before completing commercial andreputational diligence.
Grant or give any financial or other advantage (e.g., gift or other favors) to a third party involvedin the transaction in an attempt to obtain a competitive advantage.
Bribe or attempt to bribe or otherwise make a “facilitation” payment to a public official.
Improper benefits are not limited to cash payments and can include favors and other, nonmonetary consideration.
Meet with any “Covered Official” (as such term is defined in the Lobbying Disclosure Act)
without the prior approval of ACAMS’ Legal Department.

Proper Behaviors:
By way of illustration and not limitation, ACAMS, its employees, and third parties when acting on
ACAMS’ behalf, are required to:-13

Carry out due diligence by collecting and analyzing information about counterparties prior tocontract execution.
Throughout the business relationship, monitor counterparties’ compliance with anti-corruption
obligations.

ACAMS Code of Conduct

Annual Acknowledgement and Certification of Compliance with the Code of
Conduct
The signature below signifies acknowledgement that I have received and reviewed ACAMS’ Code of
Conduct. I agree to comply with the standards of conduct, policies, and procedures referenced in thisCode. I agree to report any known or suspected violations of this Code, Company policies or procedures,or applicable laws or regulations to the Vice President of Legal or their designee.
I further certify that I am not currently aware of any known or suspected violations of this Code,Company policies or procedures, or applicable law or regulation involving the Company’s businessactivities unless otherwise disclosed.
Date: _________________________
Printed Name: ___________________________________
Signature: ___________________________________________________

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