Email Disclaimer:
The contents of this email and the accompanying materials (this "Message") are confidential and for the sole use of the intended recipient. This communication may contain privileged material. If you are not the intended recipient or the person responsible for delivering the e-mail to the intended recipient, be advised that you have received this e-mail in error and that any use, dissemination, forwarding, printing, or copying of this e-mail and any file attachments is not allowed by the sender of this e-mail or Zanbato Securities LLC. If you have received this e-mail from us in error please notify the sender immediately by e-mail or by telephone at +1 650.557.2333 and permanently delete this transmission and its contents.
This communication shall not constitute an offer to sell or the solicitation of an offer to buy any securities in any jurisdiction nor does it constitute investment advice. This Message, along with any other communications between the sender and the recipient, may be monitored by Zanbato Securities LLC.
All securities transactions are effected through Zanbato Securities LLC, member FINRA/SIPC. Zanbato Securities LLC is registered with the CFTC and is a member of the NFA as an Introducing Broker (NFA No. 508365). This e-mail may include a solicitation to buy or sell a product that may contain commodity futures or options on commodity futures. Futures and options trading involves substantial risk and is not for everyone. Such investments may not be appropriate for the recipient.
The valuation of securities, futures and options may fluctuate, and, as a result, clients may lose more than their original investment. Nothing contained in this message may be construed as an express or an implied promise, guarantee or implication by, of, or from Zanbato Securities LLC that you will profit or that losses can or will be limited in any manner whatsoever. Past performance is not necessarily indicative of future results. Although care has been taken to ensure the accuracy, completeness and reliability of the information contained herein, Zanbato Securities LLC makes no warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, reliability or usefulness of any information, product, service or process disclosed.
Important Investment Banking Disclosures
Please note that Zanbato Securities LLC may have received assignments that are not publicly known and that we are not obliged to reveal due to client confidentiality. Zanbato Securities may be engaged by underlying issuers, by buyers, and by sellers, so conflicts of interest may arise in the normal course of business. The firm has policies and procedures in place designed to identify and manage such potential conflicts.
Important Disclosures for Canadian Residents
In Canada, the information is intended solely for Permitted Clients (as such term is defined in National Instrument 31-103) with whom Zanbato Securities LLC deals pursuant to the international dealer exemption. To the extent that the information references securities of an issuer incorporated, formed or created under the laws of Canada or a province or territory of Canada, any trades in such securities may not be conducted through Zanbato Securities LLC. No securities commission or similar regulatory authority in Canada has reviewed or in any way passed upon the information contained herein or the merits of the securities described herein and any representation to the contrary is an offense.
Privacy Statement For Clients
As a ZX client, your privacy is important to us. Reflecting the Firm's commitment to protecting the privacy of your personal and organization information, we have implemented privacy policies consistent with the rules mandated by federal guidelines for financial institutions. We have also adopted policies and procedures designed to help ensure the security and confidentiality of our customers' records and information.
The Collection Of Personal and Organization Information
In order to help us provide the best level of service, better meet your financial needs, and provide the financial services that ZX offers, we may collect information from the following sources:
  • Applications and other forms we have filled out (including information such as your name, address, social security number and income);
  • Your transactions with us, our affiliates, or others (including information such as account balances and transaction history);
  • Credit reporting agencies (who provide us with your credit history and information to protect both you and ZX against fraud).
Disclosure Of Personal and Organization Information To Nonaffiliated Third Parties For Business Purposes
We may disclose the information described above to companies that are not affiliated with ZX for business purposes in the following circumstances:
  • Companies that perform administrative services on our behalf (such as vendors that provide data processing, transaction processing and printing services);
  • Our attorneys, accountants, and compliance consultants.
Disclosure Of Personal and Organization Information In Other Instances
ZX currently does not share confidential personal information with third parties not affiliated with the Firm, other than our attorneys, accountants, compliance consultants, and contraparties on transactions. Please feel free to contact our Compliance Department at +1.866.ZANBATO if you have any additional questions. In addition, we may also disclose the information described above to nonaffiliated third parties as permitted by law, for example, to comply with a subpoena, respond to a regulatory authority or to protect against fraud.
Information Confidentiality And Security
At ZX, we restrict access to client information to those employees who need to know such information in order to perform their job responsibilities. Employees who have access to client information must adhere to our strict security and confidentiality policies.
Sanctions Compliance Policy
Zanbato Securities LLC (“Zanbato”) is committed to complying with the sanctions laws and regulations of the United States, European Union, the United Kingdom, and the United Nations, as well as other applicable sanctions laws and regulations in the jurisdictions in which Zanbato Securities LLC operates, subject to the primacy of local laws and regulations.
Zanbato’s Global Sanctions Policy defines the minimum standards which all its entities must comply with, including:
  • Screening customers/clients and transactions globally against the sanctions lists issued by the United States, the European Union, the United Kingdom, and the United Nations.
  • Screening locally against other sanctions lists that apply to Zanbato’s operations in a particular jurisdiction.
  • Prohibiting business activity, including prohibitions on commencing or continuing relationships or providing products or services or facilitating transactions that Zanbato believes may violate applicable sanctions laws or Zanbato’s Global Sanctions Policy. This includes prohibitions on business activity with individuals or entities named on a sanctions list or activity, directly or indirectly, involving countries or territories subject to comprehensive sanctions. As of October 2019, these countries and territories include Cuba, Iran, North Korea, Syria and the Crimea region.
  • Restricting certain business activity involving, directly or indirectly, countries or persons subject to more selective or targeted sanctions programs. These sanctions apply restrictions on some types of products or services or target certain industry sectors. As of October 2019, the selective country programs prohibit transactions and services relating to:
    • the provision of funding to the Government of Belarus or Government of Zimbabwe;
    • a donation from the Government of Sudan to a U.S. Person;
    • certain debt or equity of, and certain other transactions and services involving, the Government of Venezuela1; and
    • certain debt or equity of, and certain other transactions and services involving, the Russian financial, energy and defense sectors.
  • Investigating all customer/client alerts or transactions that are stopped through Zanbato’s screening. While Zanbato seeks to investigate these alerts and transactions in a reasonable timeframe, compliance with applicable sanctions laws or Zanbato’s Global Sanctions Policy may result in delays to the processing of customer transactions while additional due diligence is conducted and information obtained on the nature of the underlying transaction or the parties involved.
  • Blocking or rejecting transactions where Zanbato is required to do so under applicable sanctions laws or regulations or Zanbato’s Global Sanctions Policy. Transactions may also be cancelled by Zanbato where they fall outside of Zanbato’s risk appetite.
  • Reporting breaches of sanctions laws to the relevant regulatory authority. This can include any attempt by a customer to evade sanctions laws.
Zanbato may agree to process certain transactions, in its sole discretion, such as those which relate to humanitarian aid or which are otherwise permitted by a license from an appropriate authority. These transactions will be considered on a case-by-case basis and must be submitted in advance to Zanbato for consideration and approval.
Zanbato may, in its sole discretion, also decide not to process transactions, provide products or services or otherwise facilitate transactions even where permitted by applicable sanctions laws and regulations where these activities fall outside of Zanbato’s risk appetite.
1 The term “Government of Venezuela” means The state and Government of Venezuela, any political subdivision, agency, or instrumentality thereof, including the Central Bank of Venezuela and Petroleos de Venezuela, S.A. (“PdVSA”), any person owned or controlled, directly or indirectly, by the foregoing, and any person who has acted or purported to act directly or indirectly for or on behalf of, any of the foregoing, including as a member of the Maduro regime.
Our Business Continuity Plan
In the event of a significant business disruption, we have a Business Continuity Plan that is designed to permit our firm to resume operations as quickly as possible, taking into account the scope and severity of the disruptive event. In a minor disruption to only our firm, or to a building housing our firm, we will transfer our operations to a local site (if necessary) and would plan to recover and resume business quickly. In a disruption affecting our business district, city, or region, we will most likely transfer our operations to a site outside of the affected area, and then attempt to recover and resume business as soon as practicable. If the business disruption is so severe that it prevents us from conducting business for any material period of time, we will notify you with regard to how you might be affected. If, after a significant business disruption, you cannot contact us as you usually do, you may email us at support@zanbato.com.
Former Customers
Information pertaining to former clients will be treated as described in this policy.
Please direct any questions related to these materials to Zanbato's Compliance Department @ compliance@zanbato.com.
Zanbato UK Ltd is authorised and regulated by the Financial Conduct Authority. Registered office: 52 Debden road,Saffron Walden,Essex, CB11 4AB. Registered in England and Wales. No.08885567.
This message and any attachments are confidential. If you have received this message in error please notify the sender and delete this email immediately.
Unauthorised dissemination,disclosure,copying or use is prohibited. We reserve the right to monitor the content of all emails sent and received by our systems. Nothing contained in this email represents investment advice, nor should be construed as such.
Please direct any questions related to these materials to Zanbato's Compliance Department @ compliance@zanbato.com.
Zanbato Securities LLC is a U.S. registered broker-dealer and FINRA/NFA/SIPC member firm. Zanbato Securities LLC and its affiliates (collectively, "Zanbato") are compensated for referring investors to alternative investment products which are managed by counterparties that Zanbato Securities represents. Alternative investment products, including but not limited to hedge funds, private equity funds, real estate, and managed futures, involve a high degree of risk, often engage in leveraging and other speculative investment practices that may increase the risk of investment loss, can be highly illiquid, are not required to provide periodic pricing or valuation information to investors, may involve complex tax structures and delays in distributing important tax information, are not subject to the same regulatory requirements as mutual funds, often charge high fees which may offset any trading profits, and in many cases the underlying investments are not transparent and are known only to the investment manager. Alternative investment performance can be volatile. An investor could lose all or a substantial amount of his or her investment. Often, alternative investment funds and account managers have total trading authority over their funds or accounts; the use of a single advisor applying generally similar trading programs could mean lack of diversification and, consequently, higher risk. There is often no secondary market for an investor's interest in alternative investments, and none is expected to develop. There may be restrictions on transferring interests in any alternative investment. Alternative investment products often execute a substantial portion of their trades on non-U.S. exchanges. Investing in foreign markets may entail risks that differ from those associated with investments in U.S. markets. Additionally, alternative investments often entail commodity trading, which involves substantial risk of loss. Performance results are generally net of applicable fees and reflect reinvestment of profits. No representation is made that any investment vehicle will or is likely to achieve its objectives or that any investor will or is likely to achieve results comparable to those shown or will make any profit at all or will be able to avoid incurring substantial losses. Past performance is no guarantee of future results.
Zanbato introduces various alternative investment products, including but not limited to hedge funds, private equity funds, real estate, futures funds and managed futures and commodities accounts, which may operate in commodities markets and foreign markets, among others, to accredited and institutional investors. Zanbato and/or its officers/ partners and/or affiliates and/or members of Singular Global (Members of Singular Global, third-party marketers of curated funds, are registered with Zanbato Securites LLC) may have a financial interest in such alternative investment products or individual portfolio companies. In working with clients, Zanbato acts in its capacity as an SEC and CFTC-registered Broker-Dealer. Although Zanbato may give securities-related advice that is incidental to its securities brokerage services, it is not an investment advisor. To the extent applicable, Commodity Trading Advisors (CTAs) may also pay Zanbato a portion of the fees they receive from accounts introduced to them by Zanbato. When acting as a Broker-Dealer, Zanbato enters into selling agreements with counterparties including, but not limited to hedge fund managers, private equity fund managers, and futures fund managers that it represents (including funds sponsored by affiliates), pursuant to which Zanbato, with respect to the interests it sells, is paid, in general, a portion of the management and/or performance fees charged by the funds or their managers in respect of those interests generally ranging between 20% and 30% of the management fees and incentive allocation charged by the manager or between 50 and 300 basis points of the aggregate funds funded and introduced, contingent upon the transactional situation. These compensatory parameters do not have any effect on the net fees that the investor would be accountable for by the alternative investment product if the investor had made a direct investment in the alternative investment product without the introduction of Zanbato Securities LLC.
The information contained in the individual fund materials distributed to accredited investors upon request, including investment returns, valuations, fund targets and strategies, has been supplied by third party sources, including the funds and their managers or other representatives and, although believed to be reliable, this information has not been independently verified and cannot be guaranteed. Zanbato Securities LLC makes no representations or warranties as to the accuracy, timeliness or completeness of such information. Financial indicators and benchmarks are unmanaged, do not reflect any management fees, generally assume reinvestment of income, are for illustration purposes only, and have limitations when used for such purposes because they may have volatility, credit, or other material characteristics that are different from a particular investment vehicle. This material is confidential, is intended only for the person to whom it has been sent and under no circumstance may a copy be shown, copied, transmitted, or otherwise given to any person other than the intended recipient. Although Zanbato may provide summary information, Zanbato does not conduct or provide "due diligence" on an investor's behalf and is not responsible for an investor's investment decisions. All investors should consult with their professional investment counsel and tax experts to evaluate the full merits and suitability of any investment opportunity being considered.
Please direct any questions related to these materials to Zanbato's Compliance Department @ compliance@zanbato.com.
When considering alternative investments you should consider various risks, including the fact that some products use leverage and other speculative investment practices that may increase the risk of investment loss, can be illiquid, are not required to provide periodic pricing or valuation information to investors, may involve complex tax structures and delays in distributing important tax information, are not subject to the same regulatory requirements as mutual funds, often charge high fees, and in many cases the underlying investments are not transparent and are known only to the investment manager.
With respect to alternative investments in general, you should be aware that:
Returns from some alternative investments can be volatile. You may lose all or portion of your investment. With respect to single manager fund products, the manager has total trading authority. The single manager could mean a lack of diversification and higher risk. Many alternative investments are subject to substantial expenses that must be offset by trading profits and other income. Trading may take place on foreign exchanges that may not offer the same regulatory protection as U.S. exchanges.
With respect to an investment in a fund, you should be aware that:
There is often a lack of transparency as to the fund's underlying investments. As to fund of funds, the fund's manager has complete discretion to invest in various sub-funds without disclosure thereof to you or to us. Because of this lack of transparency, there is no way for you to monitor the specific investments made by the fund or to know whether the sub- fund investments are consistent with the fund's historic investment philosophy or risk levels. A fund of funds invests in other funds and fees are charged at both the fund and sub-fund level. Thus, the overall fees you will pay will be higher than you would pay by investing directly in the sub-funds. In addition, each sub-fund charges an incentive fee on new profits regardless of whether the overall operations of the fund are profitable. There is no secondary market for fund interests. Transfers of interests are subject to limitations. The fund's manager may deny a request to transfer if it determines that the transfer may result in adverse legal or tax consequences for the fund.
A fund's offering materials or a manager's disclosure document describes the various risks and conflicts of interest relating to an investment and to its operations. You should read those documents carefully to determine whether an investment is suitable for you in light of, among other things, your financial situation, need for liquidity, tax situation, and other investments.
Futures: The risk of loss in investing in alternative investments and trading or investing in futures and commodities can be substantial. You should, therefore, carefully consider whether such activity is suitable for you in light of your circumstances and financial resources. You should be aware of the following points:
(1) You may sustain a total loss of the funds that you deposit with the alternative fund manager to establish or maintain positions in the futures/commodity market, and you may incur losses beyond these amounts. If the market moves against the manager, you may be called upon to deposit a substantial amount of additional margin funds, on short notice, in order to maintain the positions. If the required funds are not provided within the required time, the positions may be liquidated at a loss, which may result in additional liability for deficits in the account.
(2) The funds deposited with an alternative investment manager transacting in futures/commodities are not protect by insurance in the event of the bankruptcy or insolvency of the manager, or in the event your funds are misappropriated.
(3) The funds deposited are not protected by the Securities Investor Protection Corporation even if the futures/commodity manager is registered with the Securities and Exchange Commission as a broker or dealer.
Keep in mind that the past performance of any investment is not necessarily indicative of future results. You should only commit risk capital to a fund investment. Alternative investment products, including hedge funds, are not for everyone and entail risks that are different from more traditional investments. You should obtain investment and tax advice from your advisers before deciding to invest.
Not all products and services described on this website are available in all jurisdictions, and certain investments may not be suitable for all investors. Certain investment products that are available to U.S. persons have not been registered with any federal or state regulator, and as a result are available only to certain qualified investors. Qualifications vary from product to product. You may notify Zanbato in writing, at any time, to remove your name from any of its product distribution lists. The information on this website should not be construed as investment advice. You should obtain independent investment and tax advice before deciding to invest. This information is for informational purposes only and is provided on an "as is" basis. Zanbato and its affiliates expressly disclaim all warranties of originality, merchantability, of fitness for any particular purpose. Without limiting the foregoing, in no event will Zanbato or its affiliates and employees have any liability in connection with the use by any person of the information or data presented in this correspondence or on this website.
Please direct any questions related to these materials to Zanbato's Compliance Department @ compliance@zanbato.com.