First Sentier Investors (Ireland) 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:
MUFG BANK, LTD.
(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) 
PRUDENTIAL REGULATION AUTHORITY

2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
02/09/2017
 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:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE PRUDENTIAL REGULATION AUTHORITY ("PRA") IMPOSED A FINE OF 17.85M POUNDS ON MUFG AND A FINE OF 8.925MPOUNDS ON MUFG
SECURITIES EMEA PLC FOR FAILING TO BE OPEN AND COOPERATIVE WITH THE PRA IN RELATION TO AN ENFORCEMENT ACTION ON MUFG BY THE NEW
YORK DEPARTMENT OF FINANCIAL SERVICES
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:
Settled
11. Resolution Date (MM/DD/YYYY):
02/09/2017
 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: $ 10,847,445.00
 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: 
THE PRUDENTIAL REGULATION AUTHORITY ("PRA") IMPOSED A FINE OF 17.85M POUNDS ON MUFG AND A FINE OF8.925M POUNDS ON MUFG
SECURITIES EMEA PLC FOR FAILING TO BE OPEN AND COOPERATIVE WITH THE PRA INRELATION TO AN ENFORCEMENT ACTION ON MUFG BY THE
NEW YORK DEPARTMENT OF FINANCIAL SERVICES
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).
THE PRUDENTIAL REGULATION AUTHORITY ("PRA") IMPOSED A FINE OF 17.85M POUNDS ON MUFG AND A FINE OF 8.925MPOUNDS ON MUFG
SECURITIES EMEA PLC FOR FAILING TO BE OPEN AND COOPERATIVE WITH THE PRA IN RELATION TOAN ENFORCEMENT ACTION ON MUFG BY THE NEW
YORK DEPARTMENT OF FINANCIAL SERVICES

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:
MUFG BANK, LTD.
(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) 
NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/18/2014
 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:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
MUFG WRONGFULLY MISLED THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (DFS) IN CONNECTION WITH ITS UNDERSTANDING OF
MUFG'S U.S. DOLLAR CLEARING SERVICES ON BEHALF OF SANCTIONED SUNDANESE, IRANIAN AND BURMESE PARTIES. UNDER THE TERMS OF THE
AGREEMENT WITH DFS, MUFG HAS MADE A PAYMENT OF US$315MILLION TO DFS. AFTER THOSE CONSENT ORDERS, MUFG TOOK ACTIONS AGAINST
PERSONS INVOLVED IN THE MATTERAT THAT TIME AND RELOCATED ITS U.S. BSA/AML AND OFAC SANCTIONS COMPLIANCE PROGRAMS TO NEW YORK.
INADDITION, DFS DESIGNATED A THIRD PARTY ORGANIZATION TO CONDUCT A COMPREHENSIVE REVIEW OF MUFG'SBSA/AML RELATED COMPLIANCE
PROGRAMS, POLICIES, AND PROCEDURES AND TO IMPLEMENT CORRECTIVE MEASURESTO ADDRESS ANY FLAWS, WEAKNESSES, OR DEFICIENCIES AS
THEY ARE IDENTIFIED. UPON MUFG'S CONVERSION TOOCC REGULATION ON NOVEMBER 7, 2017, THE DFS CONSENT ORDERS WERE REPLACED BY A
NEW OCC CONSENT ORDER,WHICH REQUIRED MUFG TO DELIVER RELATED ACTION PLANS AND REPORTS TO THE OCC SUCH THAT THE OCC
COULDREGULATE THE MATTER ON A GOING-FORWARD BASIS.
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:
Settled
11. Resolution Date (MM/DD/YYYY):
11/18/2014
 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: $ 315,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UPON MUFG'S CONVERSION TO OCC REGULATION ON NOVEMBER 7, 2017, THE DFS CONSENT ORDERS WEREREPLACED BY A NEW OCC CONSENT
ORDER, WHICH REQUIRED MUFG TO DELIVER RELATED ACTION PLANS ANDREPORTS TO THE OCC SUCH THAT THE OCC COULD REGULATE THE
MATTER ON A GOING-FORWARD BASIS.
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: 
MUFG WILL MAKE FULL PAYMENT OF A CIVIL MONETARY PENALTY OF $315,000,000 WITHIN 10 BUSINESS DAYS OFTHE CONSENT ORDER.
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).
MUFG WRONGFULLY MISLED THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (DFS) IN CONNECTION WITH ITS UNDERSTANDING OF
MUFG'S U.S. DOLLAR CLEARING SERVICES ON BEHALF OF SANCTIONED SUNDANESE, IRANIANAND BURMESE PARTIES. UNDER THE TERMS OF THE
AGREEMENT WITH DFS, MUFG HAS MADE A PAYMENT OF US$315MILLION TO DFS. AFTER THOSE CONSENT ORDERS, MUFG TOOK ACTIONS AGAINST
PERSONS INVOLVED IN THE MATTER AT THAT TIME AND RELOCATED ITS U.S. BSA/AML AND OFAC SANCTIONS COMPLIANCE PROGRAMS TO NEW YORK.
IN ADDITION, DFS DESIGNATED A THIRD PARTY ORGANIZATION TO CONDUCT A COMPREHENSIVE REVIEW OF MUFG'SBSA/AML RELATED COMPLIANCE
PROGRAMS, POLICIES, AND PROCEDURES AND TO IMPLEMENT CORRECTIVE MEASURES TO ADDRESS ANY FLAWS, WEAKNESSES, OR DEFICIENCIES AS
THEY ARE IDENTIFIED. UPON MUFG'S CONVERSION TO OCC REGULATION ON NOVEMBER 7, 2017, THE DFS CONSENT ORDERS WERE REPLACED BY A
NEW OCC CONSENT ORDER,WHICH REQUIRED MUFG TO DELIVER RELATED ACTION PLANS AND REPORTS TO THE OCC SUCH THAT THE OCC COULD
REGULATE THE MATTER ON A GOING-FORWARD BASIS.

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:
MUFG BANK, LTD.
(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) 
EUROPEAN COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/16/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:

AT.40135
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
FOREIGN EXCHANGE SPOT
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON MAY 16, 2019, THE EUROPEAN COMMISSION (THE "COMMISSION") IN A SETTLEMENT DECISION FINED AFFILIATE MUFG BANK LTD. ("MUFG BANK")
ALONG WITH SEVERAL OTHER BANKS FOR VIOLATING EUROPEAN UNION ANTITRUST RULES IN CONNECTION WITH TRADING IN THE SPOT FOREIGN
EXCHANGE MARKET FOR 11 CURRENCIES. THE COMMISSION'S INVESTIGATION FOUND THAT INDIVIDUAL TRADERS INVOLVED IN THE FOREX SPOT
TRADING OF THE CURRENCIES, WHICH INCLUDED ONE FORMER MUFG BANK TRADER WHO WAS BASED IN LONDON, HAD EXCHANGED SENSITIVE
INFORMATION AND TRADING PLANS AND OCCASIONALLY COORDINATED TRADING STRATEGIES THROUGH VARIOUS ONLINE PROFESSIONAL
CHATROOMS. THE PERIOD OF INFRINGEMENT WAS SEPTEMBER 2010 TO SEPTEMBER2011 FOR MUFG BANK.
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:
Settled
11. Resolution Date (MM/DD/YYYY):
05/16/2019
 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: $ 77,865,000.00
 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: 
THE TOTAL FINE ISSUED BY THE EUROPEAN COMMISSION AGAINST THE BANKS WAS EUR 1.07 BILLION. THEPORTION REQUIRED TO BE PAID BY
MUFG BANK LTD. WAS EUR 69,750,000 (APPROXIMATELY $77.865 MILLION).
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 MAY 16, 2019, THE EUROPEAN COMMISSION (THE "COMMISSION") IN A SETTLEMENT DECISION FINED AFFILIATE MUFG BANK LTD. ("MUFG BANK")
ALONG WITH SEVERAL OTHER BANKS FOR VIOLATING EUROPEAN UNION ANTITRUST RULES IN CONNECTION WITH TRADING IN THE SPOT FOREIGN
EXCHANGE MARKET FOR 11 CURRENCIES. THE COMMISSION'S INVESTIGATION FOUND THAT INDIVIDUAL TRADERS INVOLVED IN THE FOREX SPOT
TRADING OF THE CURRENCIES, WHICH INCLUDED ONE FORMER MUFG BANK TRADER WHO WAS BASED IN LONDON, HAD EXCHANGED SENSITIVE
INFORMATION AND TRADING PLANS AND OCCASIONALLY COORDINATED TRADING STRATEGIES THROUGH VARIOUS ONLINE PROFESSIONAL
CHATROOMS. THE PERIOD OF INFRINGEMENT WAS SEPTEMBER 2010 TO SEPTEMBER2011 FOR MUFG BANK. THE TOTAL FINE ISSUED BY THE EUROPEAN
COMMISSION AGAINST THE BANKS WAS EUR 1.07BILLION. THE PORTION REQUIRED TO BE PAID BY MUFG BANK LTD. WAS EUR 69,750,000
(APPROXIMATELY) $77.865MILLION).

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:
MUFG BANK, LTD.
(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) 
COMMODITY FUTURES TRADING COMMISSION ('CFTC')
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
02/19/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
17-21

5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Financial
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS OR CONCLUSIONS IN THE ORDER, MUFG CONSENTED TO THE ENTRYOF THE ORDER WHICH FOUND
THAT FROM AT LEAST JULY 2009 TO DECEMBER 2014, MUFG, BY AND THROUGH ONE OF ITSTRADERS LOCATED IN JAPAN, ENGAGED IN THE DISRUPTIVE
TRADING PRACTICE OF "SPOOFING" VARIOUS FUTURES PRODUCTS TRADED ON DESIGNATED CONTRACT MARKETS IN THE UNITED STATES IN VIOLATION
OF CEA SECTION 4C(A)(5)
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:
Settled
11. Resolution Date (MM/DD/YYYY):
08/07/2017
 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: $ 600,000.00
 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: 
FINED $600,000 AND ORDERED TO CEASE AND DESIST FROM VIOLATING THE COMMODITY EXCHANGE ACT'S PROHIBITION AGAINST SPOOFING.
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).
FINED $600,000 AND ORDERED TO CEASE AND DESIST FROM VIOLATING THE COMMODITY EXCHANGE ACT'S PROHIBITION AGAINST SPOOFING.

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:
MUFG BANK, LTD.
(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) 
COMPETITION COMMISSION (SWITZERLAND)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
06/06/2019
 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:
Other
Other Product Types: 
FOREIGN EXCHANGE SPOT
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON JUNE 6, 2019, SWITZERLAND'S COMPETITION COMMISSION (THE "COMPETITION COMMISSION") CONCLUDED AMICABLE SETTLEMENTS WITH
SEVERAL BANKS, INCLUDING AFFILIATE MUFG BANK LTD. ("MUFG BANK"), AND FINED THE BANKS FOR PARTICIPATING IN ANTI-COMPETITIVE
ARRANGEMENTS IN FOREIGN EXCHANGE SPOT TRADING. THE COMPETITION COMMISSION FOUND THAT TRADERS FROM THE BANKS, WHICH INCLUDED
ONE FORMER MUFG BANK TRADER WHO WAS BASED IN LONDON, PARTIALLY COORDINATED THEIR CONDUCT IN FOREIGN EXCHANGE SPOT MARKETS
FOR SEVERAL G10 CURRENCIES THROUGH THE USE OF CHATROOMS. THE RELEVANT PERIOD FOR MUFG BANK WAS SEPTEMBER 2010 TO SEPTEMBER

2011. THIS RELATES TO THE SAME ISSUE FOR WHICH MUFG BANK WAS RECENTLY FINED BY THE EUROPEAN COMMISSION IN LATE MAY 2019.
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:
Settled
11. Resolution Date (MM/DD/YYYY):
06/06/2019
 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: $ 1,499,880.00
 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: 
THE TOTAL FINE ISSUED BY SWITZERLAND'S COMPETITION COMMISSION AGAINST THE BANKS WAS APPROXIMATELY CHF 90 MILLION, AND THE
PORTION REQUIRED TO BE PAID BY MUFG BANK WAS APPROXIMATELY CHF 1.5 MILLION
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).
THE TOTAL FINE ISSUED BY SWITZERLAND'S COMPETITION COMMISSION AGAINST THE BANKS WAS APPROXIMATELY CHF 90 MILLION, AND THE
PORTION REQUIRED TO BE PAID BY MUFG BANK WAS APPROXIMATELY CHF 1.5 MILLION

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:
MUFG BANK, LTD.
(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) 
OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC)
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
02/22/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
AA-EC-2019-7
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE OCC ISSUED ON FEBRUARY 22, 2019 A CEASE AND DESIST ORDER AGAINST THE NEW YORK (PRIMARY), CHICAGO,AND LOS ANGELES FEDERAL
BRANCHES OF THE FIRM'S AFFILIATE, MUFG BANK, LTD., TOKYO, JAPAN, FOR VIOLATING THEBANK SECRECY ACT (BSA) AND ITS UNDERLYING
REGULATIONS. THE OCC FOUND THE BRANCHES' BSA COMPLIANCEPROGRAM HAD DEFICIENCIES, DATING BACK TO JUNE 2016, IN THE BRANCHES'
INTERNAL CONTROLS, SUSPICIOUS ACTIVITY MONITORING, FOREIGN CORRESPONDENT DUE DILIGENCE PROGRAM, TRADE FINANCE
MONITORING,INDEPENDENT AUDIT AND BSA OFFICER STAFFING FUNCTIONS. THESE FINDINGS CITED VIOLATION OF THE STATUTORY AND REGULATORY
REQUIREMENTS TO MAINTAIN AN ADEQUATE BSA COMPLIANCE PROGRAM, FILE SUSPICIOUS ACTIVITY REPORTS, AND CONDUCT APPROPRIATE DUE
DILIGENCE ON FOREIGN CORRESPONDENT ACCOUNTS. THE ORDER REQUIRES THE BRANCHES TO TAKE COMPREHENSIVE CORRECTIVE ACTIONS TO
IMPROVE THEIR BSA/AML COMPLIANCE PROGRAM. THE BRANCHES CONTINUE TO OPERATE UNDER AN OCC CONSENT ORDER, ISSUED IN NOVEMBER
2017,REQUIRING CORRECTIVE ACTIONS TO IMPROVE THEIR OFAC COMPLIANCE PROGRAM AND HAVE BEGUN CORRECTIVE ACTIONS AND ARE
COMMITTED TO REMEDYING THE DEFICIENCIES IDENTIFIED BY THE OCC AND ENHANCING THEIR BSA/AML COMPLIANCE PROGRAM.
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):
02/22/2019
 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: $
 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: 
THE OCC ISSUED THE ABOVE-REFERENCED CEASE AND DESIST ORDER AGAINST THE NEW YORK, CHICAGO, ANDLOS ANGELES BRANCHES OF
MUFG BANK, LTD.
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).
THE OCC ISSUED ON FEBRUARY 22, 2019 A CEASE AND DESIST ORDER AGAINST THE NEW YORK (PRIMARY), CHICAGO,AND LOS ANGELES FEDERAL
BRANCHES OF THE FIRM'S AFFILIATE, MUFG BANK, LTD., TOKYO, JAPAN, FOR VIOLATING THEBANK SECRECY ACT (BSA) AND ITS UNDERLYING
REGULATIONS. THE OCC FOUND THE BRANCHES' BSA COMPLIANCE PROGRAM HAD DEFICIENCIES, DATING BACK TO JUNE 2016, IN THE BRANCHES'
INTERNAL CONTROLS, SUSPICIOUS ACTIVITY MONITORING, FOREIGN CORRESPONDENT DUE DILIGENCE PROGRAM, TRADE FINANCE
MONITORING,INDEPENDENT AUDIT, AND BSA OFFICER STAFFING FUNCTIONS. THESE FINDINGS CITED VIOLATION OF THE STATUTORY AND REGULATORY
REQUIREMENTS TO MAINTAIN AN ADEQUATE BSA COMPLIANCE PROGRAM, FILE SUSPICIOUS ACTIVITY REPORTS, AND CONDUCT APPROPRIATE DUE
DILIGENCE ON FOREIGN CORRESPONDENT ACCOUNTS. THE ORDER REQUIRES THE BRANCHES TO TAKE COMPREHENSIVE CORRECTIVE ACTIONS TO
IMPROVE THEIR BSA/AML COMPLIANCE PROGRAM. THE BRANCHES CONTINUE TO OPERATE UNDER AN OCC CONSENT ORDER, ISSUED IN NOVEMBER
2017,REQUIRING CORRECTIVE ACTIONS TO IMPROVE THEIR OFAC COMPLIANCE PROGRAM AND HAVE BEGUN CORRECTIVE ACTIONS AND ARE
COMMITTED TO REMEDYING THE DEFICIENCIES IDENTIFIED BY THE OCC AND ENHANCING THEIR BSA/AML COMPLIANCE PROGRAM.