Allocator One

Compliance

• Architect of Regulatory Credibility
• Lead the SEC registration process as a private fund adviser (Form ADV Part 1A, 1B, and Part 2 Adviser Brochure) and manage ongoing compliance.
• Design and implement written compliance policies covering portfolio management, conflicts of interest, fiduciary duties, custody oversight, and AML/KYC frameworks.
• Conduct annual compliance reviews and testing; prepare SEC examination responses and handle any regulatory inquiries.
• Stay current with evolving SEC private fund rules (Reg PF, current enforcement priorities) and translate them into practical Infra One policies.
• Define staffing, systems, and office infrastructure requirements to meet SEC expectations for "adequate" organizational substance (not formulaic, but credible).
• Establish procedures for monitoring sub-advised GPs and ensuring they comply with fund mandates and risk limits.
• Oversee books and records management (6-year retention, email preservation, trade capture, decision logs) and coordinate with IT on cybersecurity compliance.
• Design and oversee compliance monitoring across Infra One's portfolio of funds (each with its own structure and GP).

Chief Compliance Officer, CCO