Prometheus Wealth Management Sam

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:
H2O AM LLP
(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) 
AUTORITÉ DES MARCHÉS FINANCIERS (AMF) ­ FRANCE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/30/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
SAN 2023-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
H2O AM LLP
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):
BREACHES COMMITTED IN THE MANAGEMENT OF FUNDS RELATING TO INVESTMENTS IN NOT ELIGIBLE SECURITIES DUE TO A LACK OF NECESSARY
LIABILITY TO MEET REDEMPTION REQUESTS. NO COMPLIANCE WITH THE INVESTMENT RATIO APPLICABLE TO MUTUAL FUNDS (UCITS).
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:
ON 02/21/2023, AN APPEAL WAS LODGED AGAINST THIS DECISION BEFORE THE CONSEIL D'ÉTAT (FRANCE'S SUPREME COURT FOR ADMINISTRATIVE
JUSTICE). BY JUDGMENT OF 06/13/2025 (N. 471548, 471744), THE CONSEIL D'ÉTAT DISMISSED ALL CLAIMS LODGED BY H2O AM LLP, BRUNO CRASTES
AND VINCENT CHAILLEY. THE DECISION OF THE AMF ENFORCEMENT COMMITTEE DATED 12/30/2022 IS NOW FINAL AND NO LONGER SUBJECT TO
APPEAL
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
06/13/2025
 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: $ 78,720,736.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension

B.
Other Sanctions Ordered:
IN ADDITION TO THE SANCTIONS IMPOSED ON H2O AM LLP, THE AMF ENFORCEMENT COMMITTEE IMPOSED ON MR. BRUNO CRASTES (FORMER
CEO OF H2O AM LLP) A EUR 15 MILLION FINE AND A FIVE YEAR-BAN ON OPERATING AS A MANAGER, DIRECTLY OR BY DELEGATION, AND ON MR.
VINCENT CHAILLEY (FORMER CIO) A EUR 3 MILLION FINE AND A REPRIMAND. THESE ARE INDIVIDUAL SANCTIONS, NOT SANCTIONS AGAINST H2O
AM LLP.
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: 
ON 12/30/2022, THE AMF ENFORCEMENT COMMITTEE IMPOSED ON H2O AM LLP A FINE OF EUR 75 MILLION AND A REPRIMAND FOR BREACHES
COMMITTED IN THE MANAGEMENT OF SEVEN FRENCH UCITS FUNDS RELATING TO INVESTMENTS IN INELIGIBLE FINANCIAL INSTRUMENTS,
FAILURE TO ADEQUATELY MANAGE LIQUIDITY RISK, AND NON-COMPLIANCE WITH UCITS INVESTMENT RATIOS. THE AMF ALSO IMPOSED
INDIVIDUAL SANCTIONS ON TWO FORMER EXECUTIVES: MR. BRUNO CRASTES (FORMER CEO) RECEIVED A EUR 15 MILLION FINE AND A FIVE-YEAR
BAN ON OPERATING AS A MANAGER, AND MR. VINCENT CHAILLEY (FORMER CIO) RECEIVED A EUR 3 MILLION FINE AND A REPRIMAND. H2O AM LLP
APPEALED THE DECISION TO THE CONSEIL D'ÉTAT. BY JUDGMENT OF 06/13/2025 (N. 471548, 471744), THE CONSEIL D'ÉTAT DISMISSED ALL
CLAIMS. THE FINE OF EUR 75 MILLION AGAINST H2O AM LLP (APPROXIMATELY USD 78,720,736) IS NOW FINAL AND DUE. NO PORTION OF THE
PENALTY HAS BEEN WAIVED.
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 DECISION IS NOW FINAL PER CONSEIL D'ÉTAT JUDGMENT OF 06/13/2025

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:
H2O AM LLP
(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) 
FINANCIAL CONDUCT AUTHORITY - FCA - UK
2.
Principal Sanction:
Censure
Other Sanctions: 
H2O AM LLP VOLUNTARILY CANCELLED ITS UK REGULATORY PERMISSIONS. THE H2O GROUP VOLUNTARILY SECURED THE SUM OF EUR 250 MILLION TO
BE PAID TO CURRENT UNITHOLDERS IN THE SIDE-POCKETED FUNDS AND FORMALLY WAIVED RIGHTS TO FEES AND INVESTMENTS TOTALLING EUR 320
MILLION FOR THE BENEFIT OF UNITHOLDERS.
3.
Date Initiated (MM/DD/YYYY): 
08/02/2024
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FCA NOTICE
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
H2O AM LLP
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):
BETWEEN APRIL 2015 AND NOVEMBER 2019 H2O LLP FAILED: 1) TO CONDUCT ITS BUSINESS WITH DUE SKILL, CARE AND DILIGENCE ANDTO ACT IN
THE BEST INTERESTS OF THE COLLECTIVE INVESTMENT SCHEMES ; 2) TO TAKE REASONABLE CARE TO ORGANISE AND CONTROL ITS AFFAIRS
RESPONSIBLY AND EFFECTIVELY, WITH ADEQUATE RISK MANAGEMENT SYSTEMS ; AND 3) TO DEAL WITH THE AUTHORITY IN AN OPEN AND
COOPERATIVE MANNER.
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:
Other
11. Resolution Date (MM/DD/YYYY):
08/02/2024
 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:
THE FCA IMPOSED A PUBLIC CENSURE ON H2O AM LLP PURSUANT TO SECTION 205 OF THE FINANCIAL SERVICES AND MARKETS ACT 2000. NO
FINANCIAL PENALTY WAS IMPOSED. AS PART OF THE RESOLUTION, THE H2O GROUP VOLUNTARILY SECURED EUR 250 MILLION TO BE PAID TO
CURRENT UNITHOLDERS IN THE SIDE-POCKETED FUNDS, FORMALLY WAIVED RIGHTS TO FEES AND INVESTMENTS TOTALLING EUR 320 MILLION
FOR THE BENEFIT OF UNITHOLDERS, AND H2O AM LLP AGREED TO VOLUNTARILY APPLY TO CANCEL ITS UK REGULATORY PERMISSIONS BY 31
DECEMBER 2024. H2O AM LLP IS NO LONGER AUTHORISED IN THE UK.
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: 
ON 08/02/2024, THE FCA ISSUED A FINAL NOTICE IMPOSING A PUBLIC CENSURE ON H2O AM LLP. AS PART OF THE RESOLUTION, THE H2O
GROUP VOLUNTARILY SECURED EUR 250 MILLION TO BE PAID TO CURRENT UNITHOLDERS IN THE SIDE-POCKETED FUNDS AND FORMALLY
WAIVED RIGHTS TO FEES AND INVESTMENTS TOTALLING EUR 320 MILLION FOR THE BENEFIT OF UNITHOLDERS. H2O AM LLP VOLUNTARILY
CANCELLED ITS UK REGULATORY PERMISSIONS AND IS NO LONGER AUTHORISED IN THE UK.
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 08/02/2024, THE FCA ISSUED A FINAL NOTICE IMPOSING A PUBLIC CENSURE ON H2O AM LLP. AS PART OF THE RESOLUTION, THE H2O GROUP
VOLUNTARILY SECURED EUR 250 MILLION TO BE PAID TO CURRENT UNITHOLDERS IN THE SIDE-POCKETED FUNDS BY 03/31/2025. H2O AM LLP CEASED
TO BE AUTHORISED BY THE FCA ON 07/24/2025 FOLLOWING A VOLUNTARY APPLICATION TO CANCEL ITS PERMISSIONS. THE DECISION IS FINAL AND
NOT SUBJECT TO APPEAL.