Reyl Overseas Ltd..

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.A. or
11.B. of Form ADV.
Criminal
Check item(s) being responded to:
11.A(1)
11.A(2)
11.B(1)
11.B(2)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
result in more than one affirmative answer to the items listed above.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
REYL & CIE S.A., AKA ISPWM
(For individuals, Last, First,
Middle)
CRD
Number:
5990550
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
REYL, FRANCOIS, PIERRE
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.

 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship. 
REYL & CIE S.A.; AKA ISPWM (SHAREHOLDER OF REGISTRANT), AN INVESTMENT RELATED BUSINESS, MR. FRANCOIS REYL (FORMER CHIEF EXECUTIVE
OFFICER, REYL & CIE S.A.; AKA ISPWM ).
2.
Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number). 
ON JUNE 17, 2015, REYL & CIE S.A.; AKA ISPWM AND FRANCOIS REYL WERE REFERRED FOR TRIAL TO THE PARIS CRIMINAL COURT (TRIBUNAL
CORRECTIONNEL DE PARIS), IN PARIS, FRANCE (CASE NO. 2292/13/3).
3.
Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY): 
06/17/2015
 Exact
 Explanation
If not exact, provide explanation:
B.
Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
(3) plea for each charge, and (4) product type if charge is investment-related). 
REYL & CIE S.A.; AKA ISPWM AND MR. FRANCOIS REYL WERE CHARGED WITH ONE COUNT OF ALLEGED MONEY LAUNDERING IN CONNECTION
WITH A TAX OFFENCE. THEY PLED NOT GUILTY.
C.
Did any of the Charge(s) within the Event involve a felony? 
 Yes
 No
D.
Current status of the Event? 
 Pending
 On Appeal
 Final
E.
Event Status Date (complete unless status is Pending) (MM/DD/YYYY): 
12/08/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Disposition Disclosure Detail: 
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if
sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid. 
BY A JUDGEMENT RENDERED ON DECEMBER 8, 2016, THE PARIS CRIMINAL COURT (TRIBUNAL CORRECTIONNEL DE PARIS) FOUND REYL & CIE S.A.; AKA
ISPWM AND MR. FRANCOIS REYL GUILTY OF LAUNDERING OF TAX FRAUD PROCEEDS. REYL & CIE S.A.; AKA ISPWM WAS FINED EUR 1,875,000. MR.
FRANÇOIS REYL WAS (I) FINED EUR 375,000, AND (II) TO A 12­MONTH SUSPENDED JAIL SENTENCE.
5.
Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was
the subject of the charge(s) occurred. (Your response must fit within the space provided.) 
ON 18 APRIL 2013, A FRENCH INVESTIGATING JUDGE BEGAN CRIMINAL PROCEEDINGS IN THE CONTEXT OF THE CASE AGAINST A FRENCH RESIDENT, A
CLIENT OF REYL & CIE S.A.; AKA ISPWM WHO IN 2009 HAD TRANSFERRED ASSETS AMOUNTING TO EUR 600.000 TO JULIUS BAER IN SINGAPORE. THIS
RESULTED IN THE CONDEMNATION, ON 8 DECEMBER 2016, OF REYL & CIE S.A.; AKA ISPWM , TO A FINE AMOUNTING TO EUR 1.875.000 AND FRANÇOIS
REYL TO A FINE OF EUR 375.000 TOGETHER WITH A SUSPENDED SENTENCE OF TWELVE MONTH.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.A. or
11.B. of Form ADV.
Criminal
Check item(s) being responded to:
11.A(1)
11.A(2)
11.B(1)
11.B(2)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
result in more than one affirmative answer to the items listed above.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates

One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
REYL & CIE S.A.; AKA ISPWM
(For individuals, Last, First,
Middle)
CRD
Number:
5990550
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
REYL, FRANCOIS, PIERRE
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship. 
REYL & CIE S.A.; AKA ISPWM (SHAREHOLDER OF REGISTRANT), AN INVESTMENT-RELATED BUSINESS AND MR. FRANCOIS REYL (FORMER CHIEF
EXECUTIVE OFFICER, REYL & CIE S.A.; AKA ISPWM).
2.
Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number). 
NO FORMAL CHARGES WERE OR WILL BE BROUGHT AGAINST REYL & CIE S.A.; AKA ISPWM AND MR. FRANCOIS REYL. PLEASE SEE BELOW.
3.
Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY): 
05/31/2013
 Exact
 Explanation
If not exact, provide explanation:
ON 31 MAY 2013 AN INVESTIGATION TOOK PLACE CONCERNING CLIENTS OF REYL & CIE S.A.; AKA ISPWM ALSO IN THE CONTEXT OF THE
TRANSFER OF SOME OF THEIR ASSETS TO JULIUS BAER IN SINGAPORE IN 2009.
B.
Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
(3) plea for each charge, and (4) product type if charge is investment-related). 
NO FORMAL CHARGES WERE BROUGHT AGAINST REYL & CIE S.A.; AKA ISPWM . OR MR. FRANCOIS REYL.
C.
Did any of the Charge(s) within the Event involve a felony? 
 Yes
 No
D.
Current status of the Event? 
 Pending
 On Appeal
 Final
E.
Event Status Date (complete unless status is Pending) (MM/DD/YYYY): 
01/05/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Disposition Disclosure Detail: 
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if
sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid. 
THIS LED ON 5 JANUARY 2016, TO A NON-PROSECUTION SETTLEMENT AGREEMENT CONCERNING SIX OF THESE CLIENTS, WHEREBY REYL & CIE S.A.;
AKA ISPWM AGREED TO PAY A EUR 2.8 MILLION FINE AND EUR 100,000 IN INDEMNIFICATION COSTS TO THE FRENCH STATE. FRANÇOIS REYL WAS
GRANTED A FULLY DISCHARGE.

5.
Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was
the subject of the charge(s) occurred. (Your response must fit within the space provided.) 
REYL & CIE S.A.; AKA ISPWM AND MR. FRANCOIS REYL WERE ALLEGED TO HAVE BEEN INVOLVED WITH MONEY LAUNDERING IN CONNECTION WITH TAX
EVASION ACTIVITIES OF APPROXIMATELY 32 ALLEGED CLIENTS OF REYL & CIE S.A.; AKA ISPWM. REYL & CIE S.A.; AKA ISPWM ENTERED INTO A NON-
PROSECUTION SETTLEMENT AGREEMENT ON JANUARY 5, 2016 REGARDING CLAIMS OF ALLEGED MONEY LAUNDERING RELATED TO TAX EVASION
CHARGES AGAINST SIX (6) FRENCH RESIDENTS. REYL & CIE S.A.; AKA ISPWM WAS GRANTED A DISCHARGE FROM CASES REGARDING THE REMAINING
TWENTY SIX (26) ALLEGED CLIENTS. MR. FRANCOIS REYL HAS BEEN GRANTED A COMPLETE DISCHARGE FROM THIS MATTER, AS THE JUDGES
CONSIDERED HE HAS NOT COMMITTED ANY OFFENCE.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.A. or
11.B. of Form ADV.
Criminal
Check item(s) being responded to:
11.A(1)
11.A(2)
11.B(1)
11.B(2)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
result in more than one affirmative answer to the items listed above.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
5990550
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
REYL, FRANCOIS, PIERRE
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
REYL & CIE S.A.; AKA ISPWM
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II

1.  If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship. 
REYL & CIE S.A.; AKA ISPWM (SHAREHOLDER OF REGISTRANT), AN INVESTMENT - RELATED BUSINESS AND MR. FRANCOIS REYL (FORMER CHIEF
EXECUTIVE OFFICER, REYL & CIE S.A.; AKA ISPWM ).
2.
Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number). 
NO FORMAL CHARGES WERE OR WILL BE BROUGHT AGAINST REYL & CIE S.A.; AKA ISPWM AND MR. FRANCOIS REYL. PLEASE SEE BELOW.
3.
Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY): 
05/31/2015
 Exact
 Explanation
If not exact, provide explanation:
B.
Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
(3) plea for each charge, and (4) product type if charge is investment-related). 
NO FORMAL CHARGES WERE OR WILL BE BROUGHT AGAINST REYL & CIE S.A.; AKA ISPWM AND MR. FRANCOIS REYL.
C.
Did any of the Charge(s) within the Event involve a felony? 
 Yes
 No
D.
Current status of the Event? 
 Pending
 On Appeal
 Final
E.
Event Status Date (complete unless status is Pending) (MM/DD/YYYY): 
04/18/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Disposition Disclosure Detail: 
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if
sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid. 
ON 18 APRIL 2023, REYL & CIE S.A.; AKA ISPWM AND FRANÇOIS REYL ENTERED INTO A NON­PROSECUTION SETTLEMENT AGREEMENT UNDER WHICH
REYL & CIE S.A.; AKA ISPWM HAS TO PAY EUR 5,750,000 AND MR. FRANÇOIS REYL AN AMOUNT OF EUR 500'000 IN RELATION WITH THIS LAST CLIENT.
REDUCED TO RESPECTIVELY EUR 1,0750,000 AND EUR 125,000 BY APPLICATION OF THE CONFUSION DES PEINES MECHANISM.
5.
Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was
the subject of the charge(s) occurred. (Your response must fit within the space provided.) 
AS REGARDS THE LAST CLIENT, THE FRENCH INVESTIGATING JUDGE DECIDED TO DISCONNECT THIS CASE FROM THE OTHERS AND THE
INVESTIGATIONS KEPT ON. THIS DECISION WAS BASED ON THE FACT THAT SAID CLIENT AS SUSPECTED OF HAVING USED A TRUST TO EVADE TAXES IN
FRANCE ALLTHOUGH HE HAD, AS SOON AS HE BECAME A FRENCH TAX RESIDENT, DISCLOSED THE VERY EXISTENCE OF THIS TRUST TO THE FRENCH
FISCAL AUTHORITIES BY LETTER DATED 26 NOVEMBER 2009. THE CLIENT FOUND AN AGREEMENT WITH THE FRENCH TAX AUTHORITIES FOR THE FISCAL
PROCEEDING.