Allianz Global Investors Asia Pacific Limited

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.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
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. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
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:
ALLIANZ GLOBAL INVESTORS
GMBH
(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.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
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.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
GERMAN FEDERAL FINANCIAL SUPERVISORY AUTHORITY
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/04/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ALLIANZ GLOBAL INVESTORS GMBH ("ALLIANZGI GMBH") ACQUIRED SECURITIES OF CERTAIN GERMAN ISSUERS, RESULTING IN ALLIANZGI GMBH
CONTROLLING SHARES IN EXCESS OF OWNERSHIP AND CONTROL REPORTING THRESHOLDS UNDER THE SECURITIES TRADING ACT OF THE FEDERAL
REPUBLIC OF GERMANY (THE "SECURITIES TRADING ACT"). ALLIANZGI GMBH DID NOT NOTIFY THE ISSUERS AND THE GERMAN FEDERAL FINANCIAL
SUPERVISORY AUTHORITY ("BAFIN") THAT IT HAD SURPASSED THE OWNERSHIP REPORTING THRESHOLDS WITHIN FOUR DAYS FOLLOWING THE
ACQUISITION, AS PRESCRIBED BY THE SECURITIES TRADING ACT. PURSUANT TO A SETTLEMENT OF CLAIMS, BAFIN SUBSEQUENTLY FINED ALLIANZGI
GMBH ON AUGUST 4, 2017 FOR FILING NOTIFICATIONS AFTER THE STATUTORY DEADLINE AND FOR HAVING INADEQUATE SUPERVISORY PROCESSES IN
PLACE TO COMPLY WITH ONE OF THE NOTIFICATION REQUIREMENTS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
08/04/2017
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 259,006.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, ALLIANZGI GMBH CONSENTED TO A PAYMENT TO THE FEDERAL REPUBLIC OF GERMANY IN
THE AMOUNT OF USD259,006 PLUS FEES AND EXPENSES. WHILE THE ACTUAL PAYMENT WAS MADE IN EUROS, THE AMOUNT REFLECTED ABOVE
IN ITEM 12.A. WAS CALCULATED USING THE PUBLISHED FEDERAL RESERVE FOREIGN EXCHANGE RATE OF [1.1773] AS OF 4 AUG 2017.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, ALLIANZGI GMBH CONSENTED TO A PAYMENT TO THE FEDERAL REPUBLIC OF GERMANY IN THE
AMOUNT OF USD267,839.9.

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.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
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. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
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:
ALLIANZ GLOBAL INVESTORS
GMBH
(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.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
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.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 

COMISSION DE SURVEILLANCE DU SECTEUR FINANCIER
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/04/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
ALLIANZ GLOBAL INVESTORS GMBH, LUXEMBOURG BRANCH
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
AT THE END OF 2018, THE LUXEMBOURG FINANCIAL SUPERVISORY AUTHORITY ("CSSF") CONDUCTED AN ON-SITE INSPECTION AT ALLIANZGI IN
LUXEMBOURG, FOCUSING ON COMPLIANCE WITH ANTI-MONEY LAUNDERING REGULATIONS. SUCH INSPECTIONS ARE STANDARD. DURING THIS
INSPECTION, FORMAL / ADMINISTRATIVE VIOLATIONS OF RELEVANT LUXEMBURG GUIDELINES WERE IDENTIFIED, RELATING IN PARTICULAR TO THE
ORGANIZATIONAL STRUCTURE AND ALLIANZ GLOBAL INVESTORS GMBH, LUXEMBURG BRANCH'S INTERNAL GUIDELINES AND PROCESSES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
04/04/2025
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 310,610.89
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
FINE OF EUR 283,000. WHILE THE ACTUAL PAYMENT WAS MADE IN EUROS, THE AMOUNT REFLECTED ABOVE IN ITEM 12.A. WAS CALCULATED
USING THE EXCHANGE RATE OF [1.09756] AS OF 4 APRIL 2025.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON APRIL 4, 2025, THE COMMISSION DE SURVEILLANCE DU SECTEUR FINANCIER (CSSF) PUBLISHED A FINE OF EUR 283,000 WHICH WAS IMPOSED ON
ALLIANZ GLOBAL INVESTORS GMBH, LUXEMBOURG BRANCH ("ALLIANZGI LUX"). THE FINE WAS BASED ON AN ON-SITE INSPECTION ON ALLIANZGI LUX
BY THE CSSF IN 2018, DURING WHICH CERTAIN NON-COMPLIANT ISSUES WERE IDENTIFIED WITH RESPECT TO ALLIANZGI'S ANTI-MONEY LAUNDERING
AND COUNTER TERRORIST FINANCING ("AML/CFT") FRAMEWORK, AGAINST THE APPLICABLE LUXEMBOURG AML/CFT REGULATIONS AND GUIDELINES.
WE WISH TO HIGHLIGHT THAT THE FINDINGS OF THE ON-SITE INSPECTION WERE DOCUMENTATIONAL OR PROCEDURAL IN NATURE AND NO CASE OF
MONEY LAUNDERING TOOK PLACE. ALL FINDINGS WERE REMEDIATED IN 2022 SHORTLY AFTER THE ISSUANCE OF SUCH FINDINGS. SINCE THIS AUDIT
OUR INTERNAL AND EXTERNAL AUDITORS HAVE NOT IDENTIFIED ANY MATERIAL FINDINGS IN THE FIELD OF AML GOVERNANCE. THE FINDINGS RELATED
ONLY TO ALLIANZGI LUX AND THERE WAS NO IMPACT ON (I) FUND OPERATIONS; (II) THE INVESTMENT MANAGEMENT FUNCTIONS OF ALLIANZ GLOBAL

INVESTORS GMBH AS THE MANAGEMENT COMPANY/INVESTMENT DELEGATE OF FUNDS; AND (III) OTHER ALLIANZ GLOBAL INVESTORS' ENTITIES.
FURTHER, THIS INCIDENT DID NOT MATERIALLY AFFECT ALLIANZ GLOBAL INVESTORS GMBH'S FINANCIAL CONDITION, REGULATORY STATUS AS A
LICENSED AND OR REGULATED ENTITY, OR ABILITY TO PERFORM ITS LICENSED OR REGULATED ACTIVITY.