Investment funds managed by the Private Equity investing team within Goldman Sachs Asset Management, L.P. (“GSAM”) acquired, indirectly, the parent company of AEGIS SEF and AEGIS CTA. Following the acquisition, certain GSAM personnel from the Private Equity team (the “GSAM Board Designees”) will serve on the board of an entity that holds an indirect controlling interest in AEGIS.
GSAM is a subsidiary of The Goldman Sachs Group, Inc. (“GS Group”), but the Private Equity team within GSAM is organizationally separate from the trading and other businesses of GS Group that are involved in the public markets, and information barriers exist between those groups (outlined in further detail below).
AEGIS Information Barriers
AEGIS already maintained information-access, confidentiality, and conflicts controls designed to limit access to confidential customer, participant, and transaction information based on personnel responsibilities and legitimate business, operational, and regulatory needs.
In connection with the acquisition, additional controls will be put in place to prohibit each of AEGIS-SEF and AEGIS-CTA from sharing with affiliates, including GSAM and other GS Group entities, confidential, non-public information that separately discloses, or could reasonably be used to identify or infer: (i) a specific proposed, pending, or completed RFQ, bid, offer, order, trade, price, quantity, position, counterparty-selection decision, or other transaction-level activity; (ii) a specific participant’s or customer’s market position or trading or hedging strategy; or (iii) the identity of a participant, customer, counterparty, or natural person to the extent linked to any matter described in clauses (i) or (ii) (“Restricted Information”). These restrictions will not apply to information sharing that is reasonably necessary in the ordinary course to provide customer or participant services or facilitate transactions, including information shared with an affiliate in its capacity as a participant or potential counterparty to an RFQ or trade, or between AEGIS-SEF and AEGIS-CTA in connection with a customer transaction. These restrictions will also not apply to information presented on an aggregated or anonymized basis that does not identify, and could not reasonably be used to identify or infer, a specific participant, customer, counterparty, natural person, transaction, position, or strategy.
Goldman Sachs Information Barriers
In addition to these AEGIS-level controls, GS Group maintains information barriers and related policies and procedures designed to restrict the flow of information between personnel on different sides of applicable information barriers.
These controls are designed to restrict the sharing of confidential information regarding the AEGIS business from GSAM Private Equity personnel to GS Group public-side businesses, including trading, sales and market-making.
GSAM also is implementing a policy that will require GSAM Board Designees who receive Restricted Information in error to notify appropriate GS Legal or Compliance personnel and not to use or further share that information except as necessary to escalate and remediate the erroneous receipt of the information.