##### 



Exhibit 14.1
 BKF Capital Group, Inc.
BKF Asset Management, Inc.
New York, NY 10020
 CODE OF ETHICS
 Revised December 31, 2007




---



##### 



TABLE OF CONTENTS
 PageINTRODUCTION
    
    
    1PART I TRADING RESTRICTIONS
    
    
    21.1.
    
    Statement of General Principles
    
    
    21.2.
    
    Insider Trading and Manipulative Practices
    
    
    21.3.
    
    Initial Public Offerings
    
    
    31.4.
    
    Private Placements
    
    
    31.5.
    
    Restricted List
    
    
    41.6.
    
    Transactions in BKF Shares
    
    
    41.7.
    
    Required Personal Trading Approvals
    
    
    4PART II EMPLOYEE CONDUCT
    
    
    42.1.
    
    Personal Trading Accounts and Reports
    
    
    42.2.
    
    Conflicts of Interest
    
    
    42.3.
    
    Annual Acknowledgment
    
    
    5PART III COMPLIANCE
    
    
    53.1.
    
    Compliance Officers and Supervisory Procedures
    
    
    53.2.
    
    Recordkeeping
    
    
    5Annex A
    
    POLICIES AND PROCEDURES DESIGNED TO DETECT AND PREVENT INSIDER TRADING
    
    
    7Exhibit A
    
    EMPLOYEE ANNUAL ACKNOWLEDGMENT FORM
    
    
    12Exhibit B
    
    DIRECTOR ANNUAL ACKNOWLEDGEMENT FORM
    
    
    12




---



##### 



INTRODUCTION
    Client Account
 Employee
 Firm
 Investment Professional
 Proprietary Account
 Security i.e.
 1




---



##### 



PART I
 TRADING RESTRICTIONS
 1.1. Statement of General Principles.
  1.2. Insider Trading and Manipulative Practices.
   . Any Employee who believes that he or she may be
in possession of material non-public information should: report the matter immediately to the CEO
or CFO; not purchase or sell the securities on behalf of yourself or others, including investment
partnerships affiliated with the Firm or private accounts managed by the Firm; and not communicate
the information to anyone inside or outside of the Firm. In addition, Employees should immediately
inform the CEO or CFO if they become aware of any actual or potential violation of this policy by
an Employee.
  2




---



##### 



1.3. Initial Public Offerings
  1.4. Private Placements.
  3




---



##### 



1.5. Restricted Securities
  1.6. Transactions in BKF Shares.
  1.7. Required Personal Trading Approvals.
  PART II
 EMPLOYEE CONDUCT
 2.1. Personal Trading Accounts and Reports.
 A. Employees .
 B. Outside Board Members .
  2.2. Conflicts of Interest.
  (a)
    
    rebate, directly or indirectly, to any person, firm or
corporation any part of the compensation received from the Firm as an Employee;(b)
    
    accept, directly or indirectly, from any person, firm,
corporation or association, other than the Firm, compensation of any nature as
a bonus, commission, fee, gratuity or other consideration in connection with
any transaction on behalf of the Firm,
 4




---



##### 



(c)
    
    accept, directly or indirectly, from any person, firm,
corporation, association or other entity that does business with or on behalf
of the Firm, any gift or other thing of more than de minimis value;(d)
    
    participate in entertainment with clients, brokers and other
counterparties unless reasonably related to legitimate business purposes of the
Firm; or(e)
    
    own any stock or have, directly or indirectly, any financial
interest in any other organization engaged in any securities, financial or
related business, except for a minority stock ownership or other financial
interest in any business which is publicly owned.
  2.3. Annual Acknowledgment.
  PART III
 COMPLIANCE
 3.1. Compliance Personnel and Supervisory Procedures.
 inter
alia,
  3.2. Recordkeeping.
  5




---



##### 




    
    a list of all persons subject to the Code during the period;
    
    receipts signed by all persons subject to the Code acknowledging receipt of
copies of the Code and acknowledging that: they are subject to it;
    
    a copy of each Code of Ethics that has been in effect any time during the
period;
    
    a copy of each report filed pursuant to the Code and a record of any known
violations and actions taken as a result thereof during the period;
    
    a copy of a record of all persons who are deemed to be the General Counsel
and/or the Chief Compliance Officer; and
 6




---



##### 



Annex A
 POLICIES AND PROCEDURES
DESIGNED TO DETECT AND PREVENT INSIDER TRADING IN BKF STOCK
 Section I. Policy Statement On Insider Trading.
 A.
    (i)
    
    trading by an insider, while in possession of
material, nonpublic information;(ii)
    
    trading by a non-insider, while in possession
of material, nonpublic information, where the information either was
disclosed to the non-insider in violation of an insiders duty to keep
it confidential or was misappropriated; or(iii)
    
    an insider or a non-insider described in
clause (ii) above from communicating material nonpublic information to
others.
  B. Who is an Insider?
  C. What is Material Information?
 7




---



##### 



Wall Street Journal The
Wall Street Journal
 D. What is Nonpublic Information?
 Reuters Economic Services, Wall Street Journal
 E. Bases for Liability
    quid pro quo.
 8




---



##### 



2. Misappropriation Theory
  F. Penalties for Insider Trading.
  
    
    civil injunctions
    
    treble damages
    
    disgorgement of profits
    
    jail sentences
    
    fines for the person who committed the violation of up to the greater of
$1,000,000 or three times the amount of the profit gained or loss avoided.
  Section II. Procedures To Implement The Firms Policies Against Insider Trading.
  A. Identify Inside Information.
  9




---



##### 



Reuters Economic Services, The Wall Street Journal
  (i)
    
    Report the matter immediately(ii)
    
    Do not purchase or sell the securities on behalf of yourself or
others, including investment partnerships affiliated with the Firm or private
accounts managed by the Firm; and(iii)
    
    Do not communicate the information inside or outside the Firm
 B. Personal Securities Trading.
  C. Restricting Access to Material Nonpublic Information.
  D. Arbitrage Activities.
  E. Contacts with Third Parties.
 10




---



##### 



F. Resolving Issues Concerning Insider Trading.
  11




---



##### 



Exhibit A
 EMPLOYEE ANNUAL ACKNOWLEDGEMENT FORM
  Exhibit B
 DIRECTOR ANNUAL ACKNOWLEDGEMENT FORM
  Date
    
    Name of EmployeeSignature of Employee
 12