Firm Information This Disclosure Brochure (“Form ADV Part 2”) provides information regarding the qualifications, business practices, and the advisory services provided by American Expats in Europe LTD’s (“AEX” or “the Firm”, “we”, “us”, “ours”). We are a federally Registered Investment Adviser with the U.S. Securities and Exchange Commission (“SEC”). We were founded in 2022 and are owned and operated by Frank M. Gibney, Managing Director, and Jeremy C. Cave, Chief Operating Officer and Chief Compliance Officer. Types of Advisory Services Account Establishment Services We provide account establishment services as follows:
• Several meetings with the client (virtual and/or in person), including: o Introduction o Delivery of discovery document, risk profile assessment, disclosure documents o Review of the client’s risk profile and financial objectives o Review of current funds and recommendations o Registration for access to custodial platforms
• Completion of account opening and asset transfer forms.
• Liaise with custodians.
• Placement of initial transfer instructions. Wealth Management We typically provide a variety of wealth management services to individuals and families, in several areas of a client’s financial situation, depending on their goals, objectives, and resources. We provide customized investment management solutions for our clients. We will manage advisory accounts on a discretionary or non-discretionary basis, as agreed upon with the client. We work with each client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio allocation. We will then construct a portfolio consisting of exchange traded funds (“ETFs”), mutual funds, individual stocks and bonds, or other securities. In providing wealth management services, we may also recommend the portfolio management services of other unaffiliated independent investment advisers based on the needs of the client. Factors considered in making this determination include account size, risk tolerance, the opinion of each client and the investment philosophy of the selected independent manager. Clients should refer to the selected independent advisory firm’s Form ADV Parts 2A, 2B, or other disclosure document for a full description of the services offered. We are available to meet with clients on a regular basis, or as determined by the client, to review the account. We do not receive any compensation for the selection of other managers. We may also provide advice about any type of legacy position or investment otherwise held in client portfolios. Wrap Fee Programs A “wrap-fee” program is one that provides the client with advisory and brokerage execution services for an all-inclusive fee. The client

is not charged separate fees for the respective components of the total service. We do not sponsor, manage, or participate in a Wrap Fee Program. Tailored Relationships We tailor advisory services to the individual needs of the client. Clients may place reasonable investment restrictions on their portfolios, including bans on investing in particular industries, and investing in limited amounts of securities. All limitations and restrictions placed on accounts must be presented to us in writing. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Assets Under Management As of December 31,2023, we managed $2,569,664 in client assets; all managed on a non- discretionary basis.