SALT Fund Management LLC

SALT Fund Management LLC (also written SALT Fund Management, LLC, and marketed as the SALT Fund and, for its crypto fund, Kyber Capital) is an exempt reporting adviser registered with the Securities and Exchange Commission under file number 802-122469 and CRD 316587 since September 9, 2021, with its address in Palm Beach Gardens, Florida. Its Form ADV of March 30, 2026 lists Alexander Scaramucci and Alex Klokus as its two managing members.¹

Adviser and owners

Schedule A of the annual amendment lists "Scaramucci, Alexander, Joseph" (CRD 6960736) and "KLOKUS, ALEXANDER" (CRD 7432068), each with title "MANAGING MEMBER," each acquired 09/2021, each ownership code D ("50 percent but less than 75 percent"), and each control person "Y." The execution page is signed "ALEXANDER KLOKUS," managing member, March 30, 2026. The two ownership bands are reproduced as filed. Item 11 disclosures: none filed. Item 7.A related persons: Kyber Capital Crypto GP I LLC and SALT Equity Partners I LLC. The adviser's telephone number is the number printed on the 2016 Form D of Futurism, LLC and on the United States Patent and Trademark Office filings of ENNEA LLC.¹ The investment adviser database lists no current employment and no disclosures for Scaramucci (CRD 6960736) and no record for CRD 7432068.²

Scaramucci is the oldest son of Anthony Scaramucci, according to Bustle (August 1, 2017, citing his LinkedIn profile and the Daily Mail, which it says calls him AJ) and Fortune (September 24, 2026, quoting "his father, serial entrepreneur Anthony Scaramucci"). Neither piece mentions the SALT Fund; no Form ADV or Form D opened states a family relationship or links the adviser to SkyBridge Capital.³⁴

Funds

Item 2.B and Schedule D, Section 7.B.(1) of the Form ADV of March 30, 2026 list six funds with total private fund assets of 132,930,715 dollars, the sum of the following gross asset values.¹

Kyber Capital Crypto Fund I LP (general partner Kyber Capital Crypto GP I LLC): 54,529,900 dollars, 14 owners, 31 percent non-US owners, 1 percent held by the adviser and related persons, no annual audit, custodians Mercury Technologies and Silicon Valley Bank, administrator Securitize Fund Services; answered as a venture capital fund.

SALT Fund I, L.P. (general partner SALT Equity Partners I, LLC): 38,519,622 dollars, 106 owners, 22 percent non-US, 6 percent adviser and related persons, 8 percent held by funds of funds, audited by Frank, Rimerman and Co. LLP of San Francisco, administrator Standish Management.

SALT Fund Gene Therapy, LP: 16,432,917 dollars, 48 owners, 17 percent held by funds of funds, no audit.

SALT Fund LP Series Longevity: 14,044,756 dollars, 23 owners, 37 percent held by funds of funds, no audit.

SALT Fund LP Series Food: 7,180,412 dollars, 42 owners, 47 percent held by funds of funds, no audit.

SALT Fund Series Mental Health, LP: 2,223,108 dollars, 13 owners, 74 percent held by funds of funds, no audit.

Only SALT Fund I is audited. The funds of funds that hold between 8 and 74 percent of the five SALT funds are not named in the filing. Each fund answers "No Information Filed" for a marketer. Only the March 30, 2026 edition could be retrieved, so year-over-year changes are unknown.¹⁵

Form D history

SALT Fund I, L.P. filed a Form D on March 16, 2021 (first sale yet to occur, 25,000,000 dollars offered, signed "/s/ Alexander Scaramucci"; Scaramucci and Klokus listed as executive officers) and an amendment on July 6, 2021 (first sale March 17, 2021, 40,000,000 dollars offered, 34,585,000 dollars sold, 91 investors, duration not more than one year).⁶ Series Food, Series Longevity, Gene Therapy and Series Mental Health each filed one Form D between November 2021 and June 2022 (3,415,000, 12,425,000, 14,199,999 and 7,455,000 dollars sold; 14, 17, 43 and 12 investors) under the general partner entities "Salt GP 2 LLC" and "SALT Equity Partners I LLC," signed by attorneys-in-fact, without naming Scaramucci or Klokus.⁶

Kyber Capital Crypto Fund I LP filed one Form D, signed August 23, 2022 by "Alexander Klokus, Managing Member of Kyber Capital Crypto GP I LLC" and filed August 24, 2022. It names SALT Fund Management, LLC as investment manager, checks first sale "yet to occur," duration "more than one year," offering amount "Indefinite" and amount sold zero. The EDGAR submissions record for the fund, checked October 3, 2026, lists no later Form D or amendment.⁶

Rule 503(a)(1) of Regulation D, 17 CFR 230.503, requires a notice of sales on Form D "no later than 15 calendar days after the first sale of securities in the offering." Rule 503(a)(3)(ii) requires an amendment "to reflect a change in the information provided" as soon as practicable after the change, with exceptions for items such as amount sold and number of investors, and Rule 503(a)(3)(iii) requires an amendment "annually, on or before the first anniversary of the filing of the notice of sales on Form D or the filing of the most recent amendment ... if the offering is continuing at that time." A Form D filed before a first sale is permitted. The 2026 Form ADV reports 54,529,900 dollars of gross assets and 14 owners for Kyber, and the EDGAR record shows one Form D, no amendment and an offering marked as lasting more than a year. The filings do not show whether Kyber's owners subscribed under a different exemption, through a related vehicle, or outside the United States only (31 percent of owners are non-US), and whether the rule was complied with is a question for the Securities and Exchange Commission.⁶⁷

The Passport Foundation

The Passport Foundation (EIN 26-1580196, Wilmington, Delaware, administered by Foundation Source) reports "SALT FUND I, L.P." among its other investments of its Form 990-PF for each year from 2021 to 2024: 2021 book value 107,101 dollars and fair market value 110,416 dollars; 2022 161,117 and 220,824; 2023 179,839 and 216,521; 2024 209,774 and 201,019, with annual Schedule K-1 expenses of 5,449, 8,486, 7,696 and 7,650 dollars. It is the only investor in any SALT or Kyber fund found in a public filing (the return reports the holding as an other investment, without stating the nature of the interest); the 2024 return lists John H. Burbank III as director and president. Its holding is under one percent of the fund's reported gross assets.⁸

FTX records

The FTX creditor matrix filed January 25, 2023 (In re FTX Trading Ltd., No. 22-11068, Bankr. D. Del., Doc 574, page 102 of 116) carries creditor "THE SALT FUND" with contact lines "AJ SCARAMUCCI," "ALEX KLOKUS" and a third individual, and a second row "THE SALT FUND / AJ SCARAMUCCI," without address, amount or claim type; the matrix also has a separate row "SKYBRIDGE CAPITAL." The debtors' Updated Interested Parties List (Doc 14607-1, May 10, 2024, page 7 of 13) lists "SALT Fund Management, LLC" under "Interested Parties." The notice-parties service list attached to the Kroll affidavit (Doc 18381, Exhibit B), served June 13, 2024 with the order approving the sale of FTX's Anthropic shares, lists "The Salt Fund" with email addresses at the thesaltfund.com domain for Scaramucci and Klokus; other rows on that list carry the annotation "(Shareholder of Anthropic)" and this row does not. The claims register could not be retrieved, so no claim amount is known.⁹

At the criminal trial of Sam Bankman-Fried (United States v. Bankman-Fried, No. 22-cr-673, S.D.N.Y.), the government described Exhibit 285 on October 17, 2023 as an updated invitation from a thesaltfund.com address to an ftx.com address "among others," subject "Updated invitation: SALT fund," at Bluestone Lane, 55 Hudson Yards, on September 17, 2021, during testimony on cell-site records; the testimony names no SALT principal.¹⁰

SALT brand and the SkyBridge adversary proceeding

The conference organization's site states: "SALT was founded in 2009 by SkyBridge Capital, a leading fund of funds, but now operates as a standalone entity"; its operating company is SALT Venture Group, LLC, 527 Madison Avenue, New York. Correspondence of July 29, 2024 from SkyBridge Opportunity Fund to the Securities and Exchange Commission states that "SALT Venture Group, LLC ('SALT'), a company affiliated with SkyBridge, hosts large investment conferences."¹¹ Alex Klokus's speaker biography on the same site calls him "Founder and Managing Partner at the SALT Fund" and carries the footer of SALT Venture Group, LLC. The Form ADV of SALT Fund Management LLC lists neither SALT Venture Group nor SkyBridge as a related person, and no document opened states that SALT Fund Management LLC is owned by, licensed by or affiliated with either.¹¹¹

On November 8, 2024 FTX Trading Ltd., Island Bay Ventures Inc. and Clifton Bay Investments LLC filed adversary proceeding 24-50209 in the United States Bankruptcy Court for the District of Delaware against SkyBridge parties including SALT Venture Group LLC, Anthony Scaramucci and Brett Messing. As pleaded by the plaintiffs, it seeks to avoid and recover transfers of more than 100 million dollars: a 12 million dollar sponsorship agreement with SALT in January 2022; a 10 million dollar investment by Alameda Research Ventures in the SkyBridge Coin Fund in March 2022; and 45 million dollars paid by Island Bay on September 7, 2022 "in return for 30% membership interests in both SkyBridge II and SkyBridge GP." The complaint text does not mention Klokus, the SALT Fund, Kyber or Alexander Scaramucci. The defendants moved on January 29, 2025 to compel arbitration and dismiss, and the trust opposed on April 8, 2025; neither was opened.¹²