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Protecting Customer and Transaction Information.

Policy | Transaction Information

Protecting Customer & Transaction Information

Enhanced protections related to our backing by Private Equity at Goldman Sachs Alternatives

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Enhanced protections related to our backing by Private Equity at Goldman Sachs Alternatives

On August 31, 2026, investment funds managed by the Private Equity investing team within Goldman Sachs Asset Management, L.P. (“GSAM”) acquired AEGIS Hedging Solutions (“AEGIS-HS”), the parent company of AEGIS SEF and AEGIS CTA. Certain GSAM personnel from the Private Equity team (the “GSAM Board Designees”)  now serve on the board of an entity that holds an indirect controlling interest in AEGIS-HS.
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 public markets, and information barriers exist between those groups (outlined in further detail below).
The acquisition creates potential conflicts of interest because AEGIS is now indirectly owned by investment funds managed by a GS Group affiliate, while other GS Group affiliates may engage in business with AEGIS or its customers and participants. The controls described below are designed to address these potential conflicts and protect confidential customer, participant, and transaction information.
 

 

AEGIS INFORMATION BARRIERS

Prior to the acquisition, 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. These controls remain in place today.
In connection with the acquisition, additional controls have been adopted to prohibit personnel of each of AEGIS-HS, 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 do 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 or actual counterparty to an RFQ or trade, or between AEGIS-SEF and AEGIS-CTA in connection with a customer transaction. These restrictions also do 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. 
AEGIS-CTA has also adopted controls designed to identify and address potential preferential treatment of, or other partiality toward, affiliates in connection with its activities on behalf of customers, including circumstances in which a GS Group affiliate may be a potential counterparty to a customer transaction.

 

 

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 has also implemented a policy applicable to the GSAM Board Designees and other relevant GSAM Private Equity personnel governing the receipt, use, and disclosure of certain non-public information relating to AEGIS. Among other things, the policy prohibits covered personnel from seeking, requesting, receiving, using, or disclosing Restricted Information and imposes additional limitations on the use and disclosure of certain other non-public information, including disclosure to GS Group affiliates.
 
 

 

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