N-CSR

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

________

FORM N-CSR

________

CERTIFIED SHAREHOLDER REPORT OF REGISTERED MANAGEMENT

INVESTMENT COMPANIES

Investment Company Act File Number 811-21061

Aetos Multi-Strategy Arbitrage Fund, LLC

(Exact name of registrant as specified in charter)

________

c/o Aetos Alternatives Management, LP

875 Third Avenue, 6^th Floor

New York, NY 10022

(Address of principal executive offices) (Zip code)

Harold Schaaff

Aetos Alternatives Management, LP

875 Third Avenue, 6^th Floor

New York, NY 10022

(Name and address of agent for service)

Registrant’s telephone number, including area code: 1-212-201-2500

Date of fiscal year end: January 31

Date of reporting period: January 31, 2021

Item 1. Reports to Stockholders.

AETOS MULTI-STRATEGY ARBITRAGE FUND, LLC

AETOS DISTRESSED INVESTMENT STRATEGIES FUND, LLC

AETOS LONG/SHORT STRATEGIES FUND, LLC

(Delaware Limited Liability Companies)

Financial Statements

January 31, 2021

Table of Contents

Fund Commentaries	1
Report of Independent Registered Public Accounting Firm	4
Schedules of Investments	5
Statements of Assets and Liabilities	13
Statements of Operations	14
Statements of Changes in Members’ Capital	15
Statements of Cash Flows	17
Financial Highlights	18
Notes to Financial Statements	19
Managers and Officers of the Funds	32

The Funds file their complete schedule of portfolio holdings with the Securities and Exchange Commission for the first and third quarters of each fiscal year on Form N-PORT within sixty days after the end of each period. The Funds’ Forms N-PORT are available on the Commission’s web site at http://www.sec.gov, and may be reviewed and copied at the Commission’s Public Reference Room in Washington, DC.  Information on the operation of the Public Reference Room may be obtained by calling 1-800-SEC-0330.

A description of the policies and procedures that the Funds use to determine how to vote proxies relating to portfolio securities, as well as information relating to how the Funds voted proxies relating to portfolio securities during the most recent 12-month period ended June 30, is available (i) without charge, upon request, by calling 1-212-201-2500; and (ii) on the Commission’s website at http://www.sec.gov, and may be reviewed and copied at the commission’s Public Reference Room in Washington, DC. Information on the operation of the Public Reference Room may be obtained by calling 1-800-SEC-0330.

Aetos Multi-Strategy Arbitrage Fund, LLC

Fund Commentary 

For the year ended January 31, 2021 

(Unaudited)

The Aetos Multi-Strategy Arbitrage Fund, LLC (the “Fund”) allocates its assets among a select group of portfolio managers that utilize a variety of arbitrage strategies while seeking to produce an attractive absolute return on invested capital, largely independent of the various benchmarks associated with traditional asset classes.

The Fund includes allocations to event arbitrage, fixed income arbitrage, convertible arbitrage, and quantitative strategies. Event arbitrage managers seek to identify mispricings in securities that will be resolved through an anticipated event, which can include mergers, acquisitions, spinoffs, recapitalizations and bankruptcies (either entering into or emerging from them). Fixed income arbitrage managers seek to identify discrepancies in the prices of securities that are very closely related and arbitrage that discrepancy. Convertible arbitrage managers seek to capture options mispricings imbedded in convertibles by investing in convertibles and hedging out equity exposure. Quantitative managers pursue a variety of model-driven strategies, including trend-following strategies.

For the year ended January 31, 2021, the Fund had a total return of +6.86%.¹ For the period from commencement of investment activities on September 1, 2002 through January 31, 2021, the Fund had an annualized return of +4.44%.

The Fund delivered strong performance during the period as managers navigated a challenging market environment during the first quarter and bounced back to generate gains. All of the Fund’s underlying managers generated gains except for the Fund’s trend-following manager, which sustained a modest loss as negative performance from commodity and equity positions offset positive performance from medium-term trends in fixed income markets.

Event-driven equities in renewable energy and healthcare were also among the largest contributors during the period. In renewables, long positions in hydrogen-related companies and in a European utility generated substantial gains. In healthcare, one of the most significant winners was a position in a biopharmaceutical company focused on immunotherapies. Merger arbitrage also generated gains, benefiting from several deals in the healthcare space as well as a retail merger.

Fixed income arbitrage strategies delivered positive performance despite a challenging first quarter. Corporate bond arbitrage positions were among the larger contributors, and hedged positions across the UK yield curve also contributed to performance.

Convertible and related strategies were substantial sources of performance during the period. Our convertible arbitrage specialist was able to take advantage of pricing dislocations amid record issuance. In addition, the Fund’s managers benefited from elevated activity in special purpose acquisition companies (SPACs), including several that announced acquisitions that were well-received by the market.

¹ Returns are net of expenses and fees incurred at the Fund level and do not reflect investment management fees paid outside of the Fund.

1

Aetos Distressed Investment Strategies Fund, LLC

Fund Commentary 

For the year ended January 31, 2021 

(Unaudited)

The Aetos Distressed Investment Strategies Fund, LLC (the “Fund”) allocates its assets among a select group of portfolio managers across a variety of credit and distressed investment strategies while seeking to produce an attractive absolute return on invested capital, largely independent of the various benchmarks associated with traditional asset classes.

The Fund allocates to investment managers that buy the securities (generally bonds and bank loans) of companies that are in bankruptcy or in danger of bankruptcy, as well as other assets, such as structured products (including RMBS and CMBS) and post-reorganization equities. Managers seek to identify situations where they can buy these securities at a discount to their eventual value because traditional fixed income managers may not want to or be able to own them once they have been downgraded or are in default. The sellers may also not have the expertise and patience to go through a restructuring process. This kind of investing involves credit analysis, legal expertise and (often) negotiating ability, as the manager must determine the value of the underlying securities, the likely timing and resolution of a restructuring/refinancing process and also may need to negotiate with other creditors. Additionally, certain managers express their company-specific and market views through shorting, often with credit default swaps.

For the year ended January 31, 2021, the Fund had a total return of +3.58%.¹ For the period from commencement of investment activities on September 1, 2002 through January 31, 2021, the Fund had an annualized return of +6.62%.

The majority of the Fund’s managers generated modest gains, as the portfolio benefited from situation-specific developments across the portfolio. One of the most significant contributors was a large utility undergoing a restructuring. In mid-June, the bankruptcy court confirmed the utility’s reorganization plan, and the company successfully raised debt and equity capital to emerge from bankruptcy. Positions in the utility also profited post-reorganization as the company underwent a well-received management change and obtained approval for rate increases.

Opportunistic credit positions were also significant contributors during the period. Early in the year, short positions helped going into the selloff, and we tactically re-allocated away from this position afterwards. In addition, the Fund’s managers took advantage of market volatility in March and April to make opportunistic purchases of performing loans and bonds. Among the most significant contributors were positions in the debt of travel-related and food services companies that were trading at stressed levels despite sufficient liquidity to withstand temporary shutdowns.

Detractors from performance came from company-specific events as well as several COVID-impacted situations including a post-reorg equity position in an air travel company and a position in a company providing equipment for oil exploration and production.

¹ Returns are net of expenses and fees incurred at the Fund level and do not reflect investment management fees paid outside of the Fund.

2

Aetos Long/Short Strategies Fund, LLC

Fund Commentary 

For the year ended January 31, 2021 

(Unaudited)

The Aetos Long/Short Strategies Fund, LLC (the “Fund”) allocates its assets among a select group of portfolio managers across a variety of long/short strategies while seeking to produce an attractive absolute return on invested capital, largely independent of the various benchmarks associated with traditional asset classes. The Fund comprises managers of primarily stock portfolios that are constructed on a bottom-up, fundamental basis.

For the year ended January 31, 2021, the Fund had a total return of +3.35%.¹ For the period from commencement of investment activities on September 1, 2002 through January 31, 2021, the Fund had an annualized return of +4.93%.

The Fund generated positive performance during the period as underlying managers mostly delivered gains, with some notable exceptions. A pair of managers pursuing more value-oriented strategies detracted amid a challenging period for value equities, and the Fund’s short-biased manager also generated negative performance.

Some of the best-performing equities were those of companies benefiting from consumption patterns altered by the pandemic. These included companies in e-commerce, cloud infrastructure, digital payments, remote collaboration, telehealth, CRM software, and cybersecurity, among others. In many cases, these companies experienced a two- to three-year pull-forward of expected progress in just a few months as consumers adapted to a stay-at-home environment.

The Fund also saw gains in healthcare, where the portfolio benefited from several winners among biopharmaceuticals and diagnostics companies. These included companies that announced significant partnerships with larger technology and pharmaceutical companies to assist in the development of treatments targeting COVID-19, and companies that saw positive developments in their drug pipelines.

Among long positions, detractors for the year included COVID-19-exposed names that sold off amid pandemic-related disruptions. These included long positions in a European aerospace company, an energy services company, a pair of healthcare REITs, a REIT with significant exposure to New York City office space, and a European airline.

Short positions protected the portfolio early in March 2020 as markets sold off, but they detracted over the period as markets rebounded sharply following the announcement of vaccine trials in November. Additionally, managers’ short positions were indirectly impacted by well-publicized short squeezes in January 2021, which contributed to broader market deleveraging.

¹ Returns are net of expenses and fees incurred at the Fund level and do not reflect investment management fees paid outside of the Fund.

3

 

Report of Independent Registered Public Accounting Firm

To the Board of Managers and Members of

Aetos Multi-Strategy Arbitrage Fund, LLC

Aetos Distressed Investment Strategies Fund, LLC

Aetos Long/Short Strategies Fund, LLC

Opinions on the Financial Statements

We have audited the accompanying statements of assets and liabilities, including the schedules of investments, of Aetos Multi-Strategy Arbitrage Fund, LLC, Aetos Distressed Investment Strategies Fund, LLC, and Aetos Long/Short Strategies Fund, LLC (hereafter collectively referred to as the "Funds") as of January 31, 2021, the related statements of operations and cash flows for the year ended January 31, 2021, the statements of changes in members’ capital for each of the two years in the period ended January 31, 2021, including the related notes, and the financial highlights for each of the five years in the period ended January 31, 2021 (collectively referred to as the “financial statements”). In our opinion, the financial statements present fairly, in all material respects, the financial position of each of the Funds as of January 31, 2021, the results of each of their operations and each of their cash flows for the year then ended, the changes in each of their members’ capital for each of the two years in the period ended January 31, 2021 and each of the financial highlights for each of the five years in the period ended January 31, 2021 in conformity with accounting principles generally accepted in the United States of America.

Basis for Opinions

These financial statements are the responsibility of the Funds’ management. Our responsibility is to express an opinion on the Funds’ financial statements based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Funds in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audits of these financial statements in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud.

Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. Our procedures included confirmation of securities owned as of January 31, 2021 by correspondence with the portfolio funds, custodian, and transfer agent. We believe that our audits provide a reasonable basis for our opinions.

 

March 30, 2021

We have served as the auditor of one or more investment companies in the Aetos Funds since 2002.

PricewaterhouseCoopers LLP, PricewaterhouseCoopers Center, 300 Madison Avenue, New York, NY 10017

T: (646) 471 3000, F: (813) 286 6000, www.pwc.com/us

Aetos Multi-Strategy Arbitrage Fund, LLC

Schedule of Investments

January 31, 2021

Investments	Date(s) of Acquisition	Cost		Fair Value		Percentage of Members’ Capital (1)		Liquidity
Investments in Portfolio Funds**
Commodity Trading Advisor (3)
GSA Trend Fund LP	08/01/18 - 10/01/20	$	21,311,526	$	20,784,097	4.01	%	Daily
Total Commodity Trading Advisor			21,311,526	20,784,097		4.01
Credit - Convertible Arbitrage (4)
Aequim Arbitrage Fund LP	03/01/19 – 01/01/20		30,031,906	41,499,624		8.00		Quarterly*
Total Credit - Convertible Arbitrage			30,031,906	41,499,624		8.00

The accompanying notes are an integral part of the financial statements  5

Aetos Multi-Strategy Arbitrage Fund, LLC

Schedule of Investments

January 31, 2021

Investments	Date(s) of Acquisition	Cost		Fair Value		Percentage of Members’ Capital (1)		Liquidity
Event Driven Arbitrage (5)
Davidson Kempner Partners	07/01/06 - 07/01/12		49,041,413	90,880,805		17.52		Semi-Annual
Farallon Capital Offshore Investors, Inc.	02/01/07 - 04/01/12		45,554,327	90,722,990		17.48		Semi-Annual*
Governors Lane Onshore Fund LP	08/01/15 - 08/01/16		35,000,000	46,263,321		8.92		Quarterly*
Luxor Capital Partners Liquidating SPV, LLC	07/01/16		279,527	187,061		0.04		Liquidating
Oceanwood European Financials Capital Structure
Opportunities Segregated Portfolio	08/01/19		15,000,000	16,879,894		3.25		Quarterly*
Oceanwood Opportunities Fund L.P.	02/01/12 - 07/01/16		38,072,786	58,652,496		11.30		Quarterly
Total Event Driven Arbitrage			182,948,053	303,586,567		58.51
Fixed Income Arbitrage (6)
FFIP, L.P.	04/01/07 - 04/01/12		37,984,278	81,550,434		15.72		Annual*
Parsec Onshore Partners, L.P.	07/01/07 - 04/01/12		34,127,311	57,310,475		11.04		Monthly
Total Fixed Income Arbitrage			72,111,589	138,860,909		26.76
Total investments in Portfolio Funds			306,403,074	504,731,197		97.28
Money Market Investment
JPMorgan U.S. Government Money Market Fund,
Agency Shares, 0.006%(2) (Shares 16,239,577)			16,239,577	16,239,577		3.13
Total investments		$	322,642,651	$	520,970,774	100.41	%

* The liquidity of the Portfolio Funds may be further restricted due to withdrawal limitations.

** Non-income producing investments.

⁽¹⁾ Percentages are based on Members’ Capital of $518,850,365.

⁽²⁾ Rate disclosed is the 7-day effective yield as of 01/31/21. 

⁽³⁾ Portfolio Funds in this strategy invest in futures contracts and foreign exchange forwards contracts using a variety of systematic trading strategies to meet investment objectives, which are typically the capturing of directional moves, both long and short, across diversified portfolios of markets and asset classes. 

The accompanying notes are an integral part of the financial statements  6

Aetos Multi-Strategy Arbitrage Fund, LLC

Schedule of Investments

January 31, 2021

⁽⁴⁾ Portfolio Funds in this strategy generally look to exploit relative mispricings between securities in a company’s capital structure where the manager can go long the undervalued security and hedge out resulting equity and/or credit betas. In convertible bonds, opportunities can be found where sellers do not properly assess the value of the embedded credit and equity option components, resulting in convertibles that trade either cheap or expensive to their fundamental value. In other corporate credit situations, opportunities arise when different components of a company’s capital structure imply very different fundamental outcomes (i.e. equity near zero and debt near par), creating the opportunity to structure long and short positions that have favorable payoff profiles. Both of these strategies are implemented with the use of leverage. 

⁽⁵⁾ Portfolio Funds in this strategy invest in securities of companies involved in certain special situations, including mergers, acquisitions, asset sales, spin-offs, balance sheet restructuring, bankruptcy and other situations. These special situations constitute an “event” which the Portfolio Managers believe will trigger a change in the price of securities relative to their current price or close the gap between securities that are being arbitraged. 

⁽⁶⁾ Portfolio Funds in this strategy look to exploit mispricings between related fixed income instruments, including sovereign debt, corporate debt and derivative instruments such as futures, options and swaps. Exploitable opportunities may be found in closely related securities trading at different prices, in the value between fixed income instruments and related derivative instruments, in the shape of yield curves and in credit spreads. These strategies typically require leverage in order to exploit relatively small mispricings. 

The aggregate cost of investments for tax purposes was $466,760,059. Net unrealized appreciation on investments for tax purposes was $54,210,715 consisting of $54,668,143 of gross unrealized appreciation and $457,428 of gross unrealized depreciation.

The investments in Portfolio Funds shown above, representing 97.28% of Members’ Capital, have been fair valued using NAV as a practical expedient.

The accompanying notes are an integral part of the financial statements  7

Aetos Distressed Investment Strategies Fund, LLC

Schedule of Investments

January 31, 2021

Investments	Date(s) of Acquisition	Cost		Fair Value		Percentage of Members’ Capital (1)		Liquidity
Investments in Portfolio Funds***
Distressed - Long Biased (3)
AG Mortgage Value Partners, L.P.	05/01/13	$	1,220,424	$	2,022,075	0.65	%	Side Pockets Only
Centerbridge Credit Partners, L.P.	06/01/10 - 11/01/20		35,328,799		51,541,923	16.56		Bi-Annual**
Davidson Kempner Distressed Opportunities Fund LP	11/01/09 - 11/01/20		31,097,674		59,691,045	19.17		Annual**
Marble Ridge LP	02/01/17 - 06/01/20		7,801,299		7,129,807	2.29		Liquidating
Total Distressed - Long Biased			75,448,196		120,384,850	38.67

The accompanying notes are an integral part of the financial statements  8

Aetos Distressed Investment Strategies Fund, LLC

Schedule of Investments

January 31, 2021

Investments	Date(s) of Acquisition	Cost		Fair Value		Percentage of Members’ Capital (1)		Liquidity
Distressed - Variable Biased (4)
Anchorage Capital Partners, L.P.	09/01/08 - 11/01/20		33,601,088		59,525,685	19.12		Annual**
Aurelius Capital Partners, LP	07/01/08 - 01/01/13		23,259,994		41,806,066	13.43		Semi-Annual*
King Street Capital, L.P.	08/01/07 - 07/01/08		25,139,953		48,584,183	15.60		Quarterly*
Total Distressed - Variable Biased			82,001,035		149,915,934	48.15
Total investments in Portfolio Funds			157,449,231		270,300,784	86.82
Money Market Investment
JPMorgan U.S. Government Money Market Fund,
Agency Shares, 0.006%(2) (Shares 37,269,819)			37,269,819		37,269,819	11.97
Total investments		$	194,719,050	$	307,570,603	98.79	%

* The liquidity of the Portfolio Funds may be further restricted due to withdrawal limitations.

** All or a portion of the investment is subject to lock-up provision.

*** Non-income producing investments.

⁽¹⁾ Percentages are based on Members’ Capital of $311,331,560.

⁽²⁾ Rate disclosed is the 7-day effective yield as of 01/31/21.

⁽³⁾ Portfolio Funds in this strategy invest in securities of companies in various levels of financial distress, including bankruptcy, exchange offers, workouts, financial reorganizations and other credit-related situations. Corporate bankruptcy or distress often causes a company’s securities to trade at a discounted value. The Portfolio Funds will tend to run their investment portfolios with a long bias net exposure.

⁽⁴⁾ Portfolio Funds in this strategy invest in securities of companies in various levels of financial distress, including bankruptcy, exchange offers, workouts, financial reorganizations and other credit-related situations. Corporate bankruptcy or distress often causes a company’s securities to trade at a discounted value. The Portfolio Funds will tend to run their investment portfolios with a variable net exposure.

The aggregate cost of investments for tax purposes was $300,423,766. Net unrealized appreciation on investments for tax purposes was $7,146,837 consisting of $16,651,455 of gross unrealized appreciation and $9,504,618 of gross unrealized depreciation.

The investments in Portfolio Funds shown above, representing 86.82% of Members’ Capital, have been fair valued using NAV as a practical expedient.

The accompanying notes are an integral part of the financial statements  9

Aetos Long/Short Strategies Fund, LLC

Schedule of Investments

January 31, 2021

Investments	Date(s) of Acquisition		Cost		Fair Value		Percentage of Members’ Capital (1)			Liquidity
Investments in Portfolio Funds***
Directional Equity (3)
Egerton Capital Partners, L.P.		07/01/11 - 05/01/15	$	28,244,171	$	58,767,709		10.14	%		Monthly
Sachem Head LP		05/01/15 - 09/01/17		25,762,437		45,600,484		7.87			Quarterly*
The Children’s Investment Fund LP		05/01/20		5,000,000		6,221,500		1.07			Monthly**
Total Directional Equity				59,006,608		110,589,693		19.08

The accompanying notes are an integral part of the financial statements  10

Aetos Long/Short Strategies Fund, LLC

Schedule of Investments

January 31, 2021

Investments	Date(s) of Acquisition	Cost		Fair Value		Percentage of Members’ Capital (1)		Liquidity
Equity Hedged - Generalist (4)
Eton Park Fund, L.P.	05/01/15	39,293		49,014		0.01		Liquidating
Highfields Capital II LP	07/01/15	1,725,661		1,181,038		0.20		Liquidating
Junto Capital Partners LP	01/01/19 - 10/01/19	45,000,000		52,108,395		8.99		Quarterly*
Lakewood Capital Partners, LP	05/01/17 - 05/01/19	48,592,909		45,196,987		7.80		Quarterly
MW Market Neutral TOPS Fund	10/01/20	10,492,447		16,378,893		2.83		Monthly
MW TOPS Fund	05/01/15 - 05/01/19	26,143,993		31,386,904		5.42		Monthly
Naya Fund LP	02/01/19 - 07/01/19	29,873,598		32,845,722		5.67		Quarterly
Nitorum Fund, L.P.	12/01/17 - 06/01/19	37,718,046		43,208,432		7.45		Annual**
Viking Global Equities LP	08/01/06 - 03/01/11	16,107,423		68,690,878		11.85		Annual
Total Equity Hedged - Generalist		215,693,370		291,046,263		50.22
Equity Hedged - Sector Specialist (5)
Cadian Fund LP	05/01/10 - 11/01/13	15,459,023		44,369,659		7.66		Quarterly*
Encompass Capital Fund L.P.	06/01/15 - 07/01/16	22,235,926		40,210,401		6.94		Quarterly*
Long Pond Capital QP Fund, LP	01/01/14 - 02/01/14	26,410,798		37,637,549		6.49		Quarterly*
North River Partners, L.P.	11/01/13	16,000,533		30,728,314		5.30		Quarterly
Woodline Fund LP	08/01/20	15,000,000		16,344,082		2.82		Quarterly**
Total Equity Hedged - Sector Specialist		95,106,280		169,290,005		29.21
Short-Biased Equity (6)
Kriticos International Limited	05/01/13 - 11/01/18	40,950,929		15,871,632		2.74		Quarterly
Total Short-Biased Equity		40,950,929		15,871,632		2.74
Total investments in Portfolio Funds		410,757,187		586,797,593		101.25
Money Market Investment
JPMorgan U.S. Government Money Market Fund,
Agency Shares, 0.006%(2) (Shares 24,439,294)		24,439,294		24,439,294		4.22
Total investments		$	435,196,481	$	611,236,887	105.47	%

The accompanying notes are an integral part of the financial statements  11

Aetos Long/Short Strategies Fund, LLC

Schedule of Investments

January 31, 2021

* The liquidity of the Portfolio Funds may be further restricted due to withdrawal limitations.

** All or a portion of the investment is subject to lock-up provision.

*** Non-income producing investments.

⁽¹⁾ Percentages are based on Members’ Capital of $579,558,575.

⁽²⁾ Rate disclosed is the 7-day effective yield as of 01/31/21.

⁽³⁾ Portfolio Funds in this strategy make investments that combine long positions in undervalued common stocks or corporate bonds and short positions in overvalued common stocks or corporate bonds in order to focus on generating positive returns through the Portfolio Managers’ ability to select securities through fundamental analysis, while hedging out some portion of market risk. The Portfolio Funds will tend to run their investment portfolios with a relatively high or variable net exposure.

⁽⁴⁾ Portfolio Funds in this strategy make investments that combine long positions in undervalued common stocks or corporate bonds and short positions in overvalued common stocks or corporate bonds in order to focus on generating positive returns through the Portfolio Managers’ ability to select securities through fundamental analysis, while hedging out some portion of market risk. The Portfolio Funds will tend to run their investment portfolios with a relatively low net exposure and will invest broadly across all market sectors.

⁽⁵⁾ Portfolio Funds in this strategy make investments that combine long positions in undervalued common stocks or corporate bonds and short positions in overvalued common stocks or corporate bonds in order to focus on generating positive returns through the Portfolio Managers’ ability to select securities through fundamental analysis, while hedging out some portion of market risk. The Portfolio Funds will tend to run their investment portfolios with a relatively low net exposure and will focus on investing in specific market sectors.

⁽⁶⁾ Portfolio Funds in this strategy make investments in short positions in overvalued common stocks or corporate bonds in order to focus on generating positive returns through the Portfolio Managers’ ability to select securities through fundamental analysis, while hedging out some portion of market risk. The Portfolio Funds will tend to run their investment portfolios with a permanent net short or short-only exposure.

The aggregate cost of investments for tax purposes was $548,813,169. Net unrealized appreciation on investments for tax purposes was $62,423,718 consisting of $119,646,732 of gross unrealized appreciation and $57,223,014 of gross unrealized depreciation.

The investments in Portfolio Funds shown above, representing 101.25% of Members’ Capital, have been fair valued using NAV as a practical expedient.

The accompanying notes are an integral part of the financial statements  12

Statements of Assets and Liabilities

January 31, 2021

			Aetos
	Aetos		Distressed		Aetos
	Multi-Strategy		Investment		Long/Short
	Arbitrage		Strategies		Strategies
	Fund, LLC		Fund, LLC		Fund, LLC
Assets
Investments in Portfolio Funds and Money Market Investment, at cost	$	322,642,651	$	194,719,050	$	435,196,481
Investments in Portfolio Funds and Money Market Investment, at value	$	520,970,774	$	307,570,603	$	611,236,887
Investments in Portfolio Funds, in advance		—		5,000,000		—
Accrued income		72		181		121
Receivable for sale of investments		—		—		3,267,113
Total assets		520,970,846		312,570,784		614,504,121
Liabilities
Redemptions of Interests payable		1,497,573		707,353		34,290,912
Investment management fees payable		237,915		142,759		265,753
Professional fees payable		331,340		337,895		232,070
Board of Managers’ fees payable		21,392		21,392		21,392
Withholding Tax payable		6,926		16,693		104,093
Other accrued expenses		25,335		13,132		31,326
Total liabilities		2,120,481		1,239,224		34,945,546
Net Members’ Capital	$	518,850,365	$	311,331,560	$	579,558,575

The accompanying notes are an integral part of the financial statements  13

Statements of Operations

For the year ended January 31, 2021

				Aetos
	Aetos			Distressed			Aetos
	Multi-Strategy			Investment			Long/Short
	Arbitrage			Strategies			Strategies
	Fund, LLC			Fund, LLC			Fund, LLC
Investment income:
Dividends from money market funds	$	34,251		$	44,325		$	28,314
Total investment income		34,251			44,325			28,314
Expenses:
Investment management fees		2,709,486			1,628,860			3,887,774
Administration fees		375,942			232,371			534,405
Board of Managers’ fees		85,567			85,567			85,567
Professional fees		427,283			455,712			334,642
Custodian fees		98,675			60,379			152,555
Registration fees		14,055			11,970			62,144
Printing fees		7,551			7,552			7,551
Other expenses		17,725			15,643			17,469
Total expenses		3,736,284			2,498,054			5,082,107
Net investment loss		(3,702,033	)		(2,453,729	)		(5,053,793	)
Net realized gain/(loss) on Portfolio Funds sold		10,943,124			(18,442	)		103,136,129
Net change in unrealized appreciation/(depreciation) on investments in Portfolio Funds		26,368,243			13,122,441			(91,791,178	)
Net increase in Members’ Capital derived from investment activities	$	33,609,334		$	10,650,270		$	6,291,158

The accompanying notes are an integral part of the financial statements  14

Statements of Changes in Members’ Capital

For the year ended January 31, 2021 and January 31, 2020

	Aetos Multi-Strategy Arbitrage Fund, LLC						Aetos Distressed Investment Strategies Fund, LLC
	2/1/20–			2/1/19–			2/1/20–			2/1/19–
	1/31/21			1/31/20			1/31/21			1/31/20
From investment activities:
Net investment loss	$	(3,702,033	)	$	(3,457,757	)	$	(2,453,729	)	$	(2,205,192	)
Net realized gain/(loss) on Portfolio Funds sold		10,943,124			26,742,670			(18,442	)		4,771,587
Net change in unrealized appreciation on investments in Portfolio Funds		26,368,243			12,256,387			13,122,441			3,080,255
Net increase in Members’ Capital derived from investment activities		33,609,334			35,541,300			10,650,270			5,646,650
Distributions:
Tax withholding on behalf of foreign investors		(128,902	)		(284,186	)		(534,456	)		(674,431	)
Refund of tax withholding on behalf of foreign investors		77,221			12,753			158,167			5,628
Total distributions		(51,681	)		(271,433	)		(376,289	)		(668,803	)
Members’ Capital transactions:
Proceeds from sales of Interests		5,030,965			25,839,414			3,515,942			17,799,177
Repurchase of Interests (1)		(18,587,821	)		(31,346,378	)		(8,817,142	)		(16,141,758	)
Net increase/(decrease) in Members’ Capital derived from capital transactions		(13,556,856	)		(5,506,964	)		(5,301,200	)		1,657,419
Net increase in Members’ Capital		20,000,797			29,762,903			4,972,781			6,635,266
Members’ Capital at beginning of year		498,849,568			469,086,665			306,358,779			299,723,513
Members’ Capital at end of year	$	518,850,365		$	498,849,568		$	311,331,560		$	306,358,779

⁽¹⁾ Repurchase of Interests during the year 2/1/19 - 1/31/20 include transfers amongst the Funds.

The accompanying notes are an integral part of the financial statements  15

Statements of Changes in Members’ Capital (Concluded)

For the year ended January 31, 2021 and January 31, 2020

	Aetos Long/Short Strategies Fund, LLC
	2/1/20–			2/1/19–
	1/31/21			1/31/20
From investment activities:
Net investment loss	$	(5,053,793	)	$	(6,277,439	)
Net realized gain on Portfolio Funds sold		103,136,129			54,349,635
Net change in unrealized appreciation/(depreciation) on investments in Portfolio Funds		(91,791,178	)		52,392,529
Net increase in Members’ Capital derived from investment activities		6,291,158			100,464,725
Distributions:
Tax withholding on behalf of foreign investors		(910,557	)		(2,274,625	)
Refund of tax withholding on behalf of foreign investors		—			414
Total distributions		(910,557	)		(2,274,211	)
Members’ Capital transactions:
Proceeds from sales of Interests (1)		8,328,866			44,949,189
Repurchase of Interests		(347,576,302	)		(147,124,862	)
Net decrease in Members’ Capital derived from capital transactions		(339,247,436	)		(102,175,673	)
Net decrease in Members’ Capital		(333,866,835	)		(3,985,159	)
Members’ Capital at beginning of year		913,425,410			917,410,569
Members’ Capital at end of year	$	579,558,575		$	913,425,410

⁽¹⁾ Proceeds from sales of Interests during the year 2/1/19 – 1/31/20 include transfers amongst the Funds.

The accompanying notes are an integral part of the financial statements  16

Statements of Cash Flows

For the year ended January 31, 2021 

	Aetos			Aetos Distressed			Aetos
	Multi-Strategy			Investment			Long/Short
	Arbitrage			Strategies			Strategies
	Fund, LLC			Fund, LLC			Fund, LLC
Cash flows from operating activities
Net increase in Members’ Capital derived from investment activities	$	33,609,334		$	10,650,270		$	6,291,158
Adjustments to reconcile net increase in Members’ Capital derived from investment activities to net cash provided by operating activities Purchases of Portfolio Funds		(1,031,906	)		(32,500,000	)		(20,292,587	)
Net (Purchases)/Sales of Money Market Investments		135,168			(16,381,010	)		(22,798,413	)
Sales of Portfolio Funds		19,371,895			57,571,436			357,727,185
Net realized (gain)/loss on Portfolio Funds sold		(10,943,124	)		18,442			(103,136,129	)
Net change in unrealized (appreciation)/depreciation on Investments in Portfolio Funds		(26,368,243	)		(13,122,441	)		91,791,178
Decrease in accrued income		28,284			26,920			59,768
Increase/(decrease) in investment management fees payable		9,171			2,280			(153,092	)
Decrease in professional fees payable and other accrued expenses		(29,803	)		(8,277	)		(44,211	)
Increase in Board of Managers’ fees payable		1,017			1,017			1,017
Net cash provided by operating activities		14,781,793			6,258,637			309,445,874
Cash flows from financing activities
Tax withholding on behalf of foreign investors		(161,965	)		(546,298	)		(1,708,911	)
Refund of tax withholding on behalf of foreign investors		77,221			158,167			—
Proceeds from sales of Interests		5,030,965			3,515,942			8,328,866
Repurchases of Interests		(19,728,014	)		(9,386,448	)		(316,065,829	)
Net cash used in financing activities		(14,781,793	)		(6,258,637	)		(309,445,874	)
Net change in cash		—			—			—
Cash, beginning of year		—			—			—
Cash, end of year	$	—		$	—		$	—

The accompanying notes are an integral part of the financial statements  17

Financial Highlights

    Aetos Multi-Strategy Arbitrage Fund, LLC  

	2/1/20 - 1/31/21			2/1/19 - 1/31/20			2/1/18 - 1/31/19			2/1/17 - 1/31/18			2/1/16 - 1/31/17
Total return(1)		6.86	%		7.45	%		0.40	%		7.35	%		7.08	%
Net assets, end of period (000’s)	$	518,850		$	498,850		$	469,087		$	511,439		$	534,213
Ratios to average net assets:
Expenses(2)(3)		0.76	%		0.77	%		0.77	%		0.94	%		0.95	%
Net investment loss		(0.75	)%		(0.70	)%		(0.66	)%		(0.90	)%		(0.94	)%
Portfolio turnover rate		0.22	%		10.48	%		3.70	%		0.00	%		14.96	%

    Aetos Distressed Investment Strategies Fund, LLC  

	2/1/20 - 1/31/21			2/1/19 - 1/31/20			2/1/18 - 1/31/19			2/1/17 - 1/31/18			2/1/16 - 1/31/17
Total return(1)		3.58	%		1.88	%		(0.19	)%		3.66	%		10.98	%
Net assets, end of period (000’s)	$	311,332		$	306,359		$	299,724		$	321,895		$	409,326
Ratios to average net assets:
Expenses(2)(3)		0.84	%		0.84	%		0.84	%		0.98	%		0.97	%
Net investment loss		(0.83	)%		(0.71	)%		(0.71	)%		(0.93	)%		(0.37	)%
Portfolio turnover rate		10.39	%		1.72	%		0.66	%		5.88	%		7.30	%

    Aetos Long/Short Strategies Fund, LLC  

	2/1/20 - 1/31/21			2/1/19 - 1/31/20			2/1/18 - 1/31/19			2/1/17 - 1/31/18			2/1/16 - 1/31/17
Total return(1)		3.35	%		10.66	%		(2.08	)%		9.17	%		3.77	%
Net assets, end of period (000’s)	$	579,559		$	913,425		$	917,411		$	969,108		$	917,167
Ratios to average net assets:
Expenses(2)(3)		0.70	%		0.70	%		0.69	%		0.87	%		0.88	%
Net investment loss		(0.70	)%		(0.64	)%		(0.62	)%		(0.84	)%		(0.87	)%
Portfolio turnover rate		2.82	%		9.95	%		2.97	%		14.10	%		4.83	%

(1) Total return is calculated as the geometrically linked monthly returns of the Fund for each month during the fiscal year. The Fund’s monthly returns are calculated as the change in the Fund’s value during the month, which is determined by comparing the aggregate ending value of the Fund with the aggregate beginning value of the Fund, adjusted for cash flows related to capital contributions or withdrawals during the month. Tax withholding on behalf of certain Investors is treated as a reinvested distribution.

(2) Expense ratios do not reflect the Fund’s proportionate share of expenses of the Portfolio Funds.

(3) The expense ratios do not include the Program Fees charged separately to investors as described in Note 3 in the Notes to Financial Statements.

The accompanying notes are an integral part of the financial statements  18

Notes to Financial Statements

January 31, 2021

1. Organization

The Aetos Multi-Strategy Arbitrage Fund, LLC, the Aetos Distressed Investment Strategies Fund, LLC, and the Aetos Long/Short Strategies Fund, LLC (collectively the “Funds” or “Master Funds” and individually a “Fund” or “Master Fund”) were formed in the state of Delaware as limited liability companies. The Funds are registered under the Investment Company Act of 1940, as amended (the “1940 Act”), as closed-end, non-diversified, management investment companies. The Funds are investment companies and, accordingly, follow the investment company accounting and reporting guidance of the Financial Accounting Standards Board (“FASB”) Accounting Standards Codification (“ASC”) Topic 946 - Financial Services - Investment Companies, which is part of U.S. generally accepted accounting principles (“GAAP”). Each Fund is a fund-of-funds. The Funds seek capital appreciation by allocating their assets among a select group of private investment funds (commonly known as hedge funds) (“Portfolio Funds”) that utilize a variety of alternative investment strategies that seek to produce an attractive absolute return on invested capital, largely independent of the various benchmarks associated with traditional asset classes. Aetos Alternatives Management, LP serves as the Investment Manager to the Funds.

The Funds operate under a master fund/feeder fund structure. The Feeder Funds (as defined below) invest substantially all of their investable assets in the Master Funds. As of January 31, 2021 the Feeder Funds’ beneficial ownership of their corresponding Master Funds’ members’ capital are 86%, 88%, 85%, 1%, 1% and 2%, for the Aetos Capital Multi-Strategy Arbitrage Cayman Fund, Aetos Capital Distressed Investment Strategies Cayman Fund, Aetos Capital Long/Short Strategies Cayman Fund, Aetos Capital Multi-Strategy Arbitrage Cayman Fund II, Aetos Capital Distressed Investment Strategies Cayman Fund II and Aetos Capital Long/Short Strategies Cayman Fund II (collectively the “Feeder Funds” and individually a “Feeder Fund”) respectively. The Investment Manager may receive an additional management fee and/or an incentive fee at the feeder fund level.

The principal investment objective of each Fund is as follows:

Aetos Multi-Strategy Arbitrage Fund, LLC seeks to produce an attractive absolute return on invested capital, largely independent of the various benchmarks associated with traditional asset classes, by allocating its assets among a select group of portfolio managers that utilize a variety of arbitrage strategies.

Aetos Distressed Investment Strategies Fund, LLC seeks to produce an attractive absolute return on invested capital, largely independent of the various benchmarks associated with traditional asset classes, by allocating its assets among a select group of portfolio managers across a variety of distressed investment strategies.

Aetos Long/Short Strategies Fund, LLC seeks to produce an attractive absolute return on invested capital, largely independent of the various benchmarks associated with traditional asset classes, by allocating its assets among a select group of portfolio managers across a variety of long/short strategies.

19

Notes to Financial Statements (continued)

1. Organization (continued)

The Funds may offer, from time to time, to repurchase outstanding members’ interests (“Interests”) pursuant to written tenders by members. The Funds may offer to repurchase Interests four times each year, as of the last business day of March, June, September and December. However, repurchase offers will only be made at such times and on such terms as may be determined by the Funds’ Board of Managers (the “Board”) in its sole discretion.

Interests may be purchased on the first business day of each calendar month or at such other times as may be determined by the Board.

The following table presents the repurchase offers that occurred during the year ended January 31, 2021:

Aetos Multi-Strategy Arbitrage Fund, LLC

	Repurchase Offer #1		Repurchase Offer #2		Repurchase Offer #3		Repurchase Offer #4
Commencement Date		February 28, 2020		May 29, 2020		August 31, 2020		November 30, 2020
Repurchase Request Deadline		March 31, 2020		June 30, 2020		September 30, 2020		December 31, 2020
Repurchase Pricing Date		March 31, 2020		June 30, 2020		September 30, 2020		December 31, 2020
Amount Repurchased	$	4,064,871	$	1,517,746	$	6,031,254	$	6,973,950

Aetos Distressed Investment Strategies Fund, LLC

	Repurchase Offer #1		Repurchase Offer #2		Repurchase Offer #3		Repurchase Offer #4
Commencement Date		February 28, 2020		May 29, 2020		August 31, 2020		November 30, 2020
Repurchase Request Deadline		March 31, 2020		June 30, 2020		September 30, 2020		December 31, 2020
Repurchase Pricing Date		March 31, 2020		June 30, 2020		September 30, 2020		December 31, 2020
Amount Repurchased	$	1,870,120	$	1,232,372	$	2,875,043	$	2,839,607

Aetos Long/Short Strategies Fund, LLC

	Repurchase Offer #1		Repurchase Offer #2		Repurchase Offer #3		Repurchase Offer #4
Commencement Date		February 28, 2020		May 29, 2020		August 31, 2020		November 30, 2020
Repurchase Request Deadline		March 31, 2020		June 30, 2020		September 30, 2020		December 31, 2020
Repurchase Pricing Date		March 31, 2020		June 30, 2020		September 30, 2020		December 31, 2020
Amount Repurchased	$	105,790,436	$	112,974,450	$	124,474,351	$	4,337,065

2. Significant Accounting Policies

The Funds’ financial statements are prepared in conformity with accounting principles generally accepted in the United States of America. The following is a summary of the significant accounting policies followed by the Funds:

20 

Notes to Financial Statements (continued)

2. Significant Accounting Policies (continued)

A. Use of Estimates

The preparation of financial statements in conformity with accounting principles generally accepted in the United States of America requires the Investment Manager to make estimates and assumptions that affect the amounts reported in the financial statements and accompanying notes. Actual results could differ from these estimates, and such differences could be material.

B. Portfolio Valuation and Security Transactions

The net asset values of the Funds are determined as of the close of business at the end of each month in accordance with the valuation principles set forth below or as may be determined from time to time pursuant to policies established by the Board.

The Investment Manager has established a Valuation Committee that has oversight responsibility for the valuation of each of the Funds’ investments in Portfolio Funds. Members of the Valuation Committee include key members of the Investment Manager’s Senior Management, Compliance, Due Diligence and Risk Management teams.

Investments in Portfolio Funds are presented in the accompanying financial statements at fair value, as determined by the Funds’ Investment Manager under the general supervision of the Board. Such fair value generally represents a Fund’s pro-rata interest in the net assets of a Portfolio Fund as provided by the Portfolio Funds. As a general matter, the fair value of the Funds’ interests in Portfolio Funds will represent the amount that the Funds could reasonably expect to receive from the Portfolio Funds if the Funds’ interests were redeemed at the time of the valuation, based on information reasonably available at the time the valuation is determined and that the Funds believe to be reliable.

The Investment Manager considers information provided by the Portfolio Funds regarding the methods they use to value underlying investments in the Portfolio Funds and any restrictions on or illiquidity of the interests in the Portfolio Funds, in determining fair value.

Considerable judgment is required to interpret the factors used to develop estimates of fair value. Accordingly, the estimates may not be indicative of the amounts a Fund could realize in a current market exchange and the differences could be material to the financial statements. The use of different factors or estimation methodologies could have a significant effect on the estimated fair value.

Investments in open-end registered investment companies are valued at net asset value (“NAV”).

21 

Notes to Financial Statements (continued)

2. Significant Accounting Policies (continued)

B. Portfolio Valuation and Security Transactions (continued)

The FASB issued ASC Topic 820, Fair Value Measurements and Disclosures which establishes a fair value hierarchy and specifies that a valuation technique used to measure fair value shall maximize the use of observable inputs and minimize the use of unobservable inputs. The objective of a fair value measurement is to determine the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date (an exit price). Accordingly the fair value hierarchy gives the highest priority to valuations based upon unadjusted quoted prices in active markets for identical assets or liabilities and the lowest priority to valuations based upon unobservable inputs that are significant to the valuation. The levels of the fair value hierarchy under FASB ASC Topic 820-10-35-39 to 55 are as follows:

· Level 1 – Inputs that reflect unadjusted quoted prices in active markets for identical, unrestricted assets or liabilities that the Funds have the ability to access at the measurement date;

· Level 2 – Inputs other than quoted prices that are observable for the asset or liability either directly or indirectly, including inputs in markets that are not considered to be active.

· Level 3 – Inputs that are unobservable.

Inputs broadly refer to assumptions that market participants use to make valuation decisions, including assumptions about risk. ASC Topic 820-10-35-59 permits the Investment Manager to estimate the fair value of the investments in the Portfolio Funds at the net asset value reported by the Portfolio Funds if the net asset value is calculated in a manner consistent with the measurement principles of ASC Topic 946. The Investment Manager evaluates each Portfolio Fund individually to determine that its net asset value is calculated in a manner consistent with ASC Topic 946.

The Investment Manager also considers whether an adjustment to the net asset value reported by the Portfolio Fund is necessary based upon various factors, including, but not limited to, the attributes of the interest in the Portfolio Fund held, including the rights and obligations, and any restrictions on or illiquidity of such interests, and the fair value of such Portfolio Fund’s investment portfolio or other assets and liabilities. The net asset value reported by the Portfolio Funds may be based upon unobservable inputs and a significant change in those unobservable inputs could result in a significantly lower or higher reported net asset value reported for such Portfolio Funds.

Valuations reflected in this report are as of the report date. As a result, changes in the valuation due to market events and/or issuer related events after the report date and prior to the issuance of the report are not reflected herein.

22 

Notes to Financial Statements (continued)

2. Significant Accounting Policies (continued)

B. Portfolio Valuation and Security Transactions (continued)

The following table presents information about the level within the fair value hierarchy at which the Funds’ investments are measured as of January 31, 2021:

Aetos Multi-Strategy Arbitrage Fund, LLC
Strategy	Level 1		Level 2		Level 3		Total
Investments in Portfolio Funds (1)	$	—	$	—	$	—	$	504,731,197
Money Market Investment		16,239,577		—		—		16,239,577
Total Investments	$	16,239,577	$	—	$	—	$	520,970,774

Aetos Distressed Investment Strategies Fund, LLC
Strategy	Level 1		Level 2		Level 3		Total
Investments in Portfolio Funds (1)	$	—	$	—	$	—	$	270,300,784
Money Market Investment		37,269,819		—		—		37,269,819
Total Investments	$	37,269,819	$	—	$	—	$	307,570,603

Aetos Long/Short Strategies Fund, LLC
Strategy	Level 1		Level 2		Level 3		Total
Investments in Portfolio Funds (1)	$	—	$	—	$	—	$	586,797,593
Money Market Investment		24,439,294		—		—		24,439,294
Total Investments	$	24,439,294	$	—	$	—	$	611,236,887

⁽¹⁾ In accordance with ASC 820-10-35-54B investments in Portfolio Funds that are measured at fair value using the net asset value per share (or its equivalent) as a practical expedient have not been classified in the fair value hierarchy. The fair value amounts presented in this table are intended to permit reconciliation of the fair value hierarchy to the amounts presented in the Statements of Assets and Liabilities.

Realized gains and losses from Portfolio Fund transactions are calculated on the identified cost basis. Investments are recorded on the effective date of the subscription in the Portfolio Fund.

C. Fund Income and Expenses

Expenses are recorded on an accrual basis. Each Fund bears its own expenses including, but not limited to, any taxes and investment-related expenses incurred by the Funds (e.g., fees and expenses charged by the Portfolio Managers and Portfolio Funds, professional fees, custody and administrative fees). Most expenses of the Funds can be directly attributed to a particular Fund. Expenses which cannot be directly attributed are apportioned among the Funds based upon relative net assets or on another reasonable basis.

Dividend income is recorded on the ex-dividend date.

23 

Notes to Financial Statements (continued)

2. Significant Accounting Policies (continued)

D. Income Taxes

Each Fund intends to continue to be treated as a partnership for Federal income tax purposes. Each Member is responsible for the tax liability or benefit relating to the Member’s distributive share of taxable income or loss. Accordingly, no provision for Federal income taxes is reflected in the accompanying financial statements. The Funds withhold and pay taxes on foreign Members’ share of U.S. source income and U.S. effectively connected income, if any, allocated from Portfolio Funds to the extent such income is not exempted from withholding under the Internal Revenue Code and Regulations thereunder. The actual amount of such taxes is not known until all Form K-1s from Portfolio Funds are received, usually in the following tax year. Prior to the final determination, the amount of tax is estimated based on information available. The final tax could be different from the estimated tax and the difference could be significant. Such withholdings are recorded as distributions in the Statements of Changes in Members’ Capital, and are allocated to the individual Members’ Capital accounts to which they apply and are not an expense of the Funds.

The Investment Manager applies the authoritative guidance on accounting for and disclosure of uncertainty in tax positions, which requires the Investment Manager to determine whether a tax position of the Funds is more likely than not to be sustained upon examination, including resolution of any related appeals or litigation processes, based on the technical merits of the position. However, the Investment Manager’s conclusions regarding Accounting for Uncertainty in Income Taxes may be subject to review and adjustment at a later date based on on-going analyses of tax laws, regulations and interpretations thereof and other factors. Each of the Fund’s federal, state and local tax returns for all open tax years remains subject to examination by the Internal Revenue Service and local tax authorities.

E. Distribution Policy

The Funds have no present intention of making periodic distributions of their net investment income or capital gains, if any, to Members. The amount and frequency of distributions, if any, will be determined in the sole discretion of the Board.

F. Distributions from Portfolio Funds

Distributions from Portfolio Funds will be classified as investment income or realized gains in the Statements of Operations, or alternatively, as a decrease to the cost of the investments based on the U.S. income tax characteristics of the distribution if such information is available. In cases where the tax characteristics are not available, such distributions are generally classified as investment income.

G. Cash

Cash is defined as cash on deposit at financial institutions.

24 

Notes to Financial Statements (continued)

3. Investment Manager Fee, Related Party Transactions and Other

The Funds paid the Investment Manager a monthly management fee (the “Management Fee”) at the annual rate of 0.55% of the net asset value of each Fund as of the last day of the month (before any repurchases of Interests). The Investment Manager is responsible for providing day-to-day investment management services to the Funds, and for providing various administrative services to the Funds.

The Investment Manager may also be paid a Program Fee outside of the Funds for services rendered to investors. The Program Fee is paid directly by the investors at an annual rate of up to 0.35% of an investor’s assets in the Funds. The Program Fee may also include an annual performance-based incentive fee outside of the Funds based on the return of an investor’s account with the Investment Manager.

HedgeServ (Cayman) Ltd., a limited company incorporated in the Cayman Islands, (the “Administrator”) provides administration, accounting and investor services to the Funds. In consideration for such services, the Funds pay the Administrator a monthly fee based on their combined prior month-end net assets at an annual rate of 0.12% on the first $250 million of net assets, 0.10% on net assets between $250 million and $500 million, 0.07% on net assets between $500 million and $750 million and 0.06% on net assets over $750 million, and will reimburse the Administrator for certain out-of-pocket expenses. Each Fund is allocated its pro-rata share of the monthly fee based upon its prior month-end members’ capital adjusted for capital activity.

JPMorgan Chase Bank, N.A. acts as the custodian (the “Custodian”) for the Funds’ assets. In consideration for such services, the Funds pay the Custodian a monthly fee, based on their combined month-end portfolio market values, at an annual rate of 0.025% on the first $500 million of portfolio market value, 0.02% on portfolio market value between $500 million and $1 billion and 0.015% on portfolio market value over $1 billion. Each Fund is allocated its pro-rata share of the monthly fee based upon its month-end portfolio market value.

Each Member of the Board who is not an “interested person” of the Funds as defined by the 1940 Act receives an annual retainer of $60,000 and regular quarterly meeting fees of $6,000 per meeting (additional meeting fees are $500 per meeting). The chairman of the audit committee receives an additional annual retainer of $4,700. Any Member of the Board of Managers who is an “interested person” does not receive any annual or other fee from the Funds. All Members of the Board of Managers are reimbursed by the Funds for reasonable out-of-pocket expenses.

Net profits or net losses of the Funds for each fiscal period are allocated among and credited to or debited against the capital accounts of Members as of the last day of each fiscal period in accordance with each Member’s respective investment percentage for each Fund. Net profits or net losses are measured as the net change in the value of the net assets of a Fund during a fiscal period, before giving effect to any repurchases of Interests in the Fund, and excluding the amount of any items to be allocated among the capital accounts of the Members of the Fund, other than in accordance with the Members’ respective investment percentages.

25 

Notes to Financial Statements (continued)

4. Financial Instruments with Off-Balance Sheet Risk

In the normal course of business, the Portfolio Funds in which the Funds invest trade various financial instruments and enter into various investment activities with off-balance sheet risk. These include, but are not limited to, short selling activities, writing option contracts, use of leverage and swap contracts. The Funds’ risk of loss in these Portfolio Funds is limited to the value of their investments in the Portfolio Funds.

5. Risk Factors

Limitations on the Funds’ ability to withdraw their assets from Portfolio Funds may limit the Funds’ ability to repurchase their Interests. For example, many Portfolio Funds impose lock-up periods prior to allowing withdrawals, which can be two years or longer. After expiration of the lock-up period, withdrawals typically are permitted only on a limited basis, such as daily, monthly, quarterly, semi-annually, annually or biannually. Many Portfolio Funds may also indefinitely suspend redemptions or establish restrictions on the ability to fully receive proceeds from redemptions through the application of a redemption restriction or “gate.” In instances where the primary source of funds to repurchase Interests will be withdrawals from Portfolio Funds, the application of these lock-ups and withdrawal limitations may significantly limit the Funds’ ability to repurchase their Interests.

The Funds invest primarily in Portfolio Funds that are not registered under the 1940 Act and invest in and actively trade securities and other financial instruments using different strategies and investment techniques that may involve significant risks. Such risks include those related to the volatility of the equity, credit, and currency markets, the use of leverage associated with certain fixed income strategies, derivative contracts and in connection with short positions, the potential illiquidity of certain instruments and counterparty and broker arrangements.

Some of the Portfolio Funds in which the Funds invest may invest all or a portion of their assets in securities which are illiquid or are subject to an anticipated event. These Portfolio Funds may create “side pockets” in which to hold these securities. Side pockets are series or classes of shares which are not redeemable by the investors but which are automatically redeemed or converted back into the Portfolio Fund’s regular series or classes of shares upon the realization of those securities or the happening of some other liquidity event with respect to those securities.

These “side pockets” can often be held for long periods before they are realized, and may therefore be much less liquid than the general liquidity offered on the Portfolio Fund’s regular series or classes of shares. Should the Funds seek to liquidate their investment in a Portfolio Fund that maintains investments in a side pocket arrangement or that holds a substantial portion of its assets in illiquid securities, the Funds might not be able to fully liquidate their investments without delay, which could be considerable. In such cases, during the period until the Funds are permitted to fully liquidate the investment in the Portfolio Fund, the value of the investment could fluctuate.

26

Notes to Financial Statements (continued)

5. Risk Factors (continued)

The Portfolio Funds may utilize leverage in pursuit of achieving a potentially greater investment return. The use of leverage exposes a Portfolio Fund to additional risk including (i) greater losses from investments than would otherwise have been the case had the Portfolio Fund not used leverage to make the investments; (ii) margin calls or interim margin requirements may force premature liquidations of investment positions; and (iii) losses on investments where the investment fails to earn a return that equals or exceeds the Portfolio Fund’s cost of leverage related to such investment. In the event of a sudden, precipitous drop in the value of a Portfolio Fund’s assets, the Portfolio Fund might not be able to liquidate assets quickly enough to repay its borrowings, further magnifying the losses incurred by the Portfolio Fund.

The Portfolio Funds may invest a higher percentage of their assets in specific sectors of the market in order to achieve a potentially greater investment return. As a result, the Portfolio Funds may be more susceptible to economic, political and regulatory developments in a particular sector of the market, positive or negative, and may experience increased volatility of the Portfolio Fund’s net asset value.

The Portfolio Funds may invest in securities of foreign companies that involve special risks and considerations not typically associated with investments in the United States of America, due to concentrated investments in a limited number of countries or regions, which may vary throughout the year depending on the Portfolio Fund. Such concentrations may subject the Portfolio Funds to additional risks resulting from political or economic conditions in such countries or regions and the possible imposition of adverse governmental laws or currency exchange restrictions could cause the securities and their markets to be less liquid and their prices to be more volatile than those of comparable U.S. securities.

The Funds invest in a limited number of Portfolio Funds and such concentrations may result in additional risk. Various risks are also associated with an investment in the Funds, including risks relating to the multi-manager structure of the Funds, risks relating to compensation arrangements and risks related to limited liquidity of the Interests.

The Funds and Portfolio Funds are also subject to the risk of losses arising in connection with cybersecurity incidents.

The outbreak of the novel coronavirus disease 2019 (“COVID-19") globally continues to adversely impact global commercial activity and has contributed to significant volatility in financial markets. While, due to the evolving and highly uncertain nature of this event, it currently is not possible to estimate its impact precisely, the COVID-19 pandemic may continue to impact the performance and liquidity of the Funds’ underlying managers and their investments and therefore the financial performance and liquidity of the Funds themselves. Moreover, changes in interest rates, reduced liquidity or a continued slowdown in the United States or further deterioration of global economic conditions may also adversely affect the financial performance of the Funds and their underlying managers. Further, extreme market volatility may leave the Funds and/or the underlying managers unable to react to market events in a prudent manner consistent with historical practices in dealing with more orderly markets.

27

Notes to Financial Statements (continued) 

5. Risk Factors (continued)

In the normal course of business, the Funds enter into contracts that contain a variety of representations which provide general indemnifications. Each Fund’s maximum exposure under these arrangements is unknown as this would involve future claims that may be made against each Fund that have not yet occurred. However, based on experience, the Funds expect the risk of loss to be remote.

6. Investment Transactions

For the year ended January 31, 2021, purchases and sales of Portfolio Funds were as follows:

Fund	Purchases		Sales
Aetos Multi-Strategy Arbitrage Fund, LLC	$	1,031,906	$	19,339,989
Aetos Distressed Investment Strategies Fund, LLC		27,500,000		57,529,242
Aetos Long/Short Strategies Fund, LLC		20,292,587		360,633,713

7. Investments

As of January 31, 2021, collectively the Funds had investments in thirty-five Portfolio Funds, none of which were related parties. The agreements related to investments in Portfolio Funds provide for compensation to the general partners/managers in the form of management fees of 0% to 2.0% (per annum) of the net assets and incentive fees or allocations of 0% to 25% of net profits earned. The Portfolio Funds generally provide for periodic redemptions, with lock-up provisions ranging up to 3 years from initial investment.

The liquidity provisions shown in the following tables apply after any applicable lock-up provisions. Further liquidity detail is also provided in the Schedule of Investments.

28

Notes to Financial Statements (continued)

7. Investments (continued)

	Number of Portfolio Funds	% of Total Portfolio Funds
Aetos Multi-Strategy Arbitrage Fund, LLC
Funds allowing daily withdrawals (notice period of 1 day)	1	4.12	%
Funds allowing monthly withdrawals (notice period of 30 days)	1	11.35	%
Funds allowing quarterly withdrawals (notice periods ranging from 45 to 90 days)	4	32.35	%
Funds allowing semi-annual withdrawals (notice periods ranging from 60 to 65 days)	2	35.98	%
Funds allowing annual withdrawals (notice period of 60 days)	1	16.16	%
Funds in liquidation	1	0.04	%

	Number of Portfolio Funds	% of Total Portfolio Funds
Aetos Distressed Investment Strategies Fund, LLC
Funds allowing quarterly withdrawals (notice period of 65 days)	1	17.97	%
Funds allowing semi-annual withdrawals (notice period of 65 days)	1	15.47	%
Funds allowing annual withdrawals (notice periods ranging from 65 to 90 days)	2	44.10	%
Funds allowing bi-annual withdrawals (notice period of 90 days)	1	19.07	%
Funds fully comprised of side-pocket investments	1	0.75	%
Funds in liquidation	1	2.64	%

	Number of Portfolio Funds	% of Total Portfolio Funds
Aetos Long/Short Strategies Fund, LLC
Funds allowing monthly withdrawals (notice periods ranging from 30 to 90 days)	4	19.21	%
Funds allowing quarterly withdrawals (notice periods ranging from 30 to 65 days)	10	61.51	%
Funds allowing annual withdrawals (notice periods ranging from 45 to 60 days)	2	19.07	%
Funds in liquidation	2	0.21	%

29

Notes to Financial Statements (continued)

8. Commitments

Through March 1, 2021, the Funds had made the following commitments to purchase Portfolio Funds and made the following redemption requests from Portfolio Funds, which are effective February 28, 2021 through March 31, 2021:

Fund Purchases	Amount
Aetos Distressed Investment Strategies Fund, LLC
Carronade Capital Partners, LP	$	5,000,000

Fund Redemptions	Amount
Aetos Distressed Investment Strategies Fund, LLC
Anchorage Capital Partners, L.P.	$	3,000,000
Centerbridge Credit Partners, L.P.		3,000,000
King Street Capital, L.P.		3,000,000
Aetos Long/Short Strategies Fund, LLC
Egerton Capital Partners, L.P.		4,000,000
Encompass Capital Fund L.P.		6,000,000
Lakewood Capital Partners, LP		4,000,000
Long Pond Capital QP Fund, LP.		9,409,387
Naya Fund LP		3,000,000
Sachem Head LP		11,400,121
Viking Global Equities LP		8,000,000
Aetos Multi-Strategy Arbitrage Fund, LLC
Oceanwood European Financials Capital Structure Opportunities Segregated Portfolio	$	1,500,000

9. Subsequent Events

Through March 1, 2021, the Funds received the following contributions:

Fund	Amount
Aetos Multi-Strategy Arbitrage Fund, LLC	$	96,200
Aetos Distressed Investment Strategies Fund, LLC		60,400
Aetos Long/Short Strategies Fund, LLC		89,400

30 

Notes to Financial Statements (continued)

9. Subsequent Events (continued)

The following table summarizes the repurchase requests received by the Funds which are effective from March 31, 2021 to June 30, 2021:

Fund	Number of Investors		Estimated Redemption Amount Subsequent to 01/31/21		% of Members’ Capital
Aetos Multi-Strategy Arbitrage Fund, LLC		9	$	14,884,027		2.87	%
Aetos Distressed Investment Strategies Fund, LLC		10		63,699,511		20.46	%
Aetos Long/Short Strategies Fund, LLC		11		18,947,495		3.27	%

The Funds have evaluated the need for additional disclosures and/or adjustments resulting from subsequent events through the date the financial statements were issued. Based on this evaluation, no additional disclosures or adjustments were required to the financial statements as of January 31, 2021.

31 

Managers and Officers of the Funds (unaudited)

Name, Address(1), Age	Position(s) Held with Funds	Length of Time Served(2)	Principal Occupation(s) During the Past 5 Years/Other Directorships(3) Held by Board Member	Number of Funds in the Fund Complex Overseen by Manager(4)
Independent Managers:
Ellen Harvey 66	Manager	Since  2002	Principal, Lindsey Criswell LLC, July 2008-Present; Managing Director, Miller Investment Management,  September 2008-June 2018;  Trustee of Cutwater Select Income Fund, March 2010-Present; Trustee of Managed Duration Investment Grade Municipal Fund, November 2016-September 2018	3
Pierre de Saint Phalle 72	Manager	Since 2002	Managing Director, Promontory Financial Group, May 2006-November 2016; Senior Consultant, Promontory Financial Group, December 2016-Present	3
Warren J. Olsen 64	Manager	Since  2003	Director, The Taiwan Fund, Inc., April 2018-Present; Chairman and Chief Investment Officer, SCB Global Capital Management, July 2014-Present; Chairman and Chief Investment Officer, First Western Investment Management, September 2002-July 2014	3
Interested Managers:
Michael Klein(5) 62	Manager and President	Since 2003	Co-President and Chief Risk Officer, Aetos Alternatives Management, LP; Co-Chief Executive Officer and Managing Director, Aetos Capital, LLC, until July 2018; Director/Trustee of certain funds in the Morgan Stanley Fund Complex, August 2006-Present	3
Officers:
Anne Casscells 62	Chief Investment Officer	Since  2002	Co-President and Chief Investment Officer, Aetos Alternatives Management, LP; Co-Chief Executive Officer and Managing Director, Aetos Capital, LLC until July 2018	N/A
Scott Sawyer 52	Treasurer	Since 2004	Chief Financial Officer, Aetos Alternatives Management, LP; Director and Chief Financial Officer, Aetos Capital, LLC until July 2018	N/A
Harold J. Schaaff 60	Vice President and Secretary	Since  2001	General Counsel and Secretary, Aetos Alternatives Management, LP; General Counsel, Managing Director and Secretary, Aetos Capital, LLC until July 2018	N/A

(1) Each Manager can be contacted by writing to Aetos Alternatives Management, LP 875 Third Avenue, New York, NY 10022.

(2) Each Manager holds office until the next meeting of members at which Managers are elected following his or her election or appointment and until his successor has been elected and qualified.

(3) Directorships of companies required to report to the Securities and Exchange Commission under the Securities Exchange Act of 1934 (i.e., “public companies”) or other investment companies registered under the 1940 Act.

(4) The “Fund Complex” consists of all registered investment companies for which Aetos Alternatives Management, LP or any of its affiliates serves as investment adviser.

(5) Mr. Klein is considered to be an “interested person” of the Fund as defined in the 1940 Act because he is a Co-President of Aetos Alternatives Management, LP.

32 

Item 2. Code of Ethics.

The registrant has adopted a code of ethics that applies to the registrant’s President and Treasurer. The registrant has not granted any waivers from any provisions of the code of ethics during the covered period.

Item 3. Audit Committee Financial Expert.

(a)(1) The registrant’s Board of Managers has determined that the registrant has at least one audit committee financial expert serving on the audit committee.

(a)(2) The audit committee financial expert is Warren J. Olsen. Mr. Olsen is independent as defined in Form N-CSR Item 3(a)(2).

Item 4. Principal Accountant Fees and Services.

Fees billed by PricewaterhouseCoopers (“PwC”) related to the Fund.

PwC billed the Fund aggregate fees for services rendered to the Fund for the last two fiscal years as follows:

		Fiscal 2021			Fiscal 2020
		All fees and services to the Fund that were pre-approved	All fees and services to service affiliates that were pre-approved	All other fees and services to service affiliates that did not require pre-approval	All fees and services to the Fund that were pre-approved	All fees and services to service affiliates that were pre-approved	All other fees and services to service affiliates that did not require pre-approval
(a)	Audit Fees(1)	$44,280	$0	$0	$42,200	$0	$0
(b)	Audit-Related Fees	$0	$0	$0	$0	$0	$0
(c)	Tax Fees (2)	$241,900	$0	$0	$275,960	$0	$0
(d)	All Other Fees	$0	$0	$0	$0	$0	$0

Notes:

(1) Audit fees include amounts related to the audit of the registrant’s annual financial statements and services normally provided by the accountant in connection with statutory and regulatory filings.

(2) Tax fees relate to preparation of federal and state tax returns.

(e)(1) The audit committee has adopted pre-approval policies and procedures that require the audit committee to pre-approve all audit and non-audit services (including tax services) to be provided to the Fund and all non-auditing services to be provided to the Fund’s investment adviser (or any affiliate thereof that provides ongoing services to the Fund) if such services relate directly to operations and financial reporting of the Fund.

(e)(2) Percentage of fees billed applicable to non-audit services pursuant to waiver of pre-approval requirement were as follows:

	Fiscal 2021	Fiscal 2020
Audit-Related Fees	0%	0%
Tax Fees	0%	0%
All Other Fees	0%	0%

(f) Not applicable.

(g) The aggregate amount of non-audit fees and services billed by PwC to: (i) the Fund, and (ii) Aetos Alternatives Management, LP, the Fund’s investment adviser (the “Investment Manager”) and any entity controlling, controlled by, or under common control with the Investment Manager that provides ongoing services to the Fund for the last two fiscal years were $781,300 and $812,150 for Fiscal 2021 and Fiscal 2020, respectively.

(h) During the past fiscal year no non-audit services were provided by the registrant’s principal accountant to either the registrant’s investment adviser or to any entity controlling, controlled by, or under common control with the registrant’s investment adviser that provides ongoing services to the registrant, that were not pre-approved by the audit committee.

Item 5. Audit Committee of Listed Registrants.

Not applicable.

Item 6. Schedule of Investments

Included as part of the report to shareholders filed under Item 1 of this Form.

Item 7. Disclosure of Proxy Voting Policies and Procedures for Closed-End Management Investment Companies.

Aetos Alternatives Management, LP

Proxy Voting Policy

I. Introduction

This policy sets forth Aetos Alternatives Management, LP (“AAM”) policies and procedures for voting proxies with respect to portfolio securities held in the accounts for which AAM provides discretionary investment management services and for which AAM has the explicit authority to vote their proxies. The policy will be reviewed and, if necessary, updated periodically to address new or revised proxy voting issues as they arise.

As an investment manager for various clients, including clients governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), AAM may vote proxies as part of its authority to manage, acquire and dispose of client account assets, unless the “named fiduciary” for an ERISA account has explicitly reserved the authority for itself, or in the case of an account not governed by ERISA, the client investment management agreement does not provide that AAM will vote proxies. When voting proxies for client accounts, AAM will make voting decisions solely in the best interests of its clients and its ERISA plan clients and beneficiaries and participants, considering all relevant factors and without undue influence from individuals or groups who may have an economic interest in the outcome of a proxy vote. In fulfilling its obligations to its clients, AAM will act in a manner it deems prudent and diligent and which is intended to enhance the economic value of the underlying portfolio securities held in its clients’ accounts.

II. Routine Corporate Matters

AAM will generally, although not always, vote in support of management on matters which are common management-sponsored initiatives, provided that, in AAM’s opinion, approval of such initiatives will not detract from the economic value of the company’s securities held in AAM client accounts. These matters are set out below:

(i) Appointment or election of auditors;

(ii) Routine elections or re-elections of directors;

(iii) Director’s liability and indemnification;

(iv) General updating/corrective amendments to charter;

(v) Name changes;

(vi) Elimination of cumulative voting; and

(vii) Elimination of preemptive rights.

III. Issues Having the Potential for Major Economic Impact

A. AAM will generally, although not always, vote in support of management initiatives which may have a substantive financial or best interest impact, provided that, in AAM’s opinion, approval of such initiatives will not detract from the economic value of the company’s securities held in AAM client accounts. These matters are set out below:

(i) Capitalization changes which eliminate other classes of stock and voting rights;

(ii) Changes in capitalization authorization for stock splits, stock dividends, and other specified needs which are no more than 50% of the existing authorization;

(iii) Stock purchase plans with an exercise price of not less than 85% of fair market value;

(iv) Stock option plans that are incentive based and not excessive;

(v) Other stock-based plans which are appropriately structured;

(vi) Reductions in supermajority vote requirements; and

(vii) Adoption of anti-greenmail provisions.

B. AAM will generally not vote in support of management on certain issues which have a potential substantive financial or best interest impact when AAM believes that approval of the proposal may negatively impact the economic value of the company’s securities held in AAM client accounts. These matters are set out below:

(i) Capitalization changes which add classes of stock which are blank check in nature or that dilute the voting interests of existing shareholders;

(ii) Changes in capitalization authorization where management does not offer an appropriate rationale or that are contrary to the best interest of existing shareholders;

(iii) Anti-takeover and related provisions which serve to prevent the majority of shareholders from exercising their rights or effectively deter appropriate tender offers and other offers;

(iv) Amendments to by-laws which would require supermajority shareholder votes to pass or repeal certain provisions;

(v) Classified boards of directors;

(vi) Reincorporation into a state which has more stringent anti-takeover and related provisions;

(vii) Shareholder rights plans which allow appropriate offers to shareholders to be blocked by the board or trigger provisions which prevent legitimate offers from proceeding;

(viii) Excessive compensation or non-salary compensation related proposals;

(ix) Change-in-control provisions in non-salary compensation plans, employment contracts and severance agreements that benefit management and would be costly to shareholders if triggered; and

(x) “Other business as properly comes before the meeting” proposals which give a blank check to those acting as proxy.

IV. Social and Corporate Responsibility Issues

AAM, believing that management’s job is to handle ordinary business matters, and not wanting to arbitrarily impose a judgment on such matters, usually votes with management on these proposals. Third party analyses of these issues are taken into account. If an issue will, in our view negatively impact the investment merits of a company, we will oppose it.

V. Conflict of Interests

Situations may arise where there are material conflicts between AAM’s interest and those of its advisory clients. AAM may resolve potential conflicts by using any of the following methods: (1) adopting a policy of disclosing the conflict to clients and obtaining their consent before voting: (2) basing the proxy vote on pre-determined voting guidelines if the application of the guidelines to the matter do not involve the exercise of discretion on the part of AAM; or (3) using the recommendations of an independent third party.

VI. Proxy Voting Record Retention

AAM retains the following records: (1) proxy voting policies and procedures; (2) proxy statements; (3) records of votes cast on behalf of clients; (4) records of clients’ requests for proxy voting information; and (5) any documents prepared by or on behalf of AAM that were material in making decisions on how to vote. AAM retains the above-mentioned records for a minimum of five years.

VII. Proxy Administration

The decision on how to vote a proxy will generally be made by the investment professional responsible for the security requesting a shareholder vote. The investment professional will consult with the Compliance Officer prior to making any such determination, and the Compliance Officer will determine if the proposed vote is consistent with the policies set forth in II-IV above, in which case no further action is required, or the proposed vote is not in compliance with these guidelines or presents a conflict, in which case the proxy will be reviewed with senior management, who will determine the appropriate vote.

Item 8. Portfolio Managers of Closed-End Management Investment Companies

(a)(1)

Investment Management Team

Name & Title (Years of Service)
Jonathan Bishop
Managing Director and Portfolio Manager, Aetos Alternatives Management, LP (formerly Aetos Alternatives Management, LLC) (7)	Managing Director and Portfolio Manager, Aetos Alternatives Management LP (formerly Aetos Alternatives Management, LLC); Director, Aetos Capital, LLC, until July 2018.

Anne Casscells
Co-President and Chief Investment Officer, Aetos Alternatives Management, LP (formerly Aetos Alternatives Management, LLC)  (19)	Co-President and Chief Investment Officer, Aetos Alternatives Management, LP (formerly Aetos Alternatives Management, LLC); Co-Chief Executive Officer and Managing Director, Aetos Capital, LLC, until July 2018.
Abby Chen
Managing Director and Portfolio Manager, Aetos Alternatives Management, LP (formerly Aetos Alternatives Management, LLC) (1)	Managing Director and Portfolio Manager, Aetos Alternatives Management LP (formerly Aetos Alternatives Management, LLC), April 2021 to Present; Managing Director, Aetos Alternatives Management LP, January 2020 to March 2021; Director, Aetos Alternatives Management LP, until December 2019.
Filbert Cua
Managing Director and Portfolio Manager, Aetos Alternatives Management, LP (formerly Aetos Alternatives Management, LLC) (1)	Managing Director and Portfolio Manager, Aetos Alternatives Management LP (formerly Aetos Alternatives Management, LLC), April 2021 to Present; Managing Director, Aetos Alternatives Management LP, January 2020 to March 2021; Director, Aetos Alternatives Management LP, until December 2019.
James Gibbons
Managing Director and Portfolio Manager, Aetos Alternatives Management, LP (formerly Aetos Alternatives Management, LLC)  (19)	Managing Director and Portfolio Manager, Aetos Alternatives Management LP (formerly Aetos Alternatives Management, LLC);  Managing Director, Aetos Capital, LLC, until July 2018.
Michael Klein
Co-President and Chief Risk Officer, Aetos Alternatives Management, LP (formerly Aetos Alternatives Management, LLC)  (19)	Co-President and Chief Risk Officer, Aetos Alternatives Management, LP (formerly Aetos Alternatives Management, LLC); Co-Chief Executive Officer and Managing Director, Aetos Capital, LLC, until July 2018.

The information provided in response to this Item 8(a)(1) is provided as of April 01, 2021.

(a)(2)(i), (ii), (iii)

The following tables show information regarding accounts (other than the Fund) managed by each named portfolio manager as of January 31, 2021.

Jonathan Bishop Anne Casscells James Gibbons Michael Klein	Number of Accounts	Total Assets in Accounts ($ million)	Number of Accounts where Advisory Firm’s Fee is Based on Account Performance	Total Assets in Accounts where Advisory Firm’s Fee is Based on Account Performance ($ million)
Registered Investment Companies	2	$891	N/A	N/A
Other Pooled Investment Vehicles	1	$33	1	$33
Other Accounts	14	$7,379	3	$634

(a)(2)(iv)

Material Conflicts of Interest

The Investment Manager manages multiple accounts for multiple clients. The Investment Manager has adopted compliance procedures that are designed to ensure that each client is treated equitably with respect to the presentation of investment opportunities. In practice, the Investment Manager allocates investment opportunities across client relationships generally on a pro-rata basis among accounts for which such investments are suitable, subject to a number of factors, including cash availability, each client’s investment objectives and risk tolerance, the make-up of each client’s remaining portfolio at the time of investment and the size of the potential investment relative to the client’s portfolio size. As a result of the application of these and other considerations, opportunities will not always be allocated to all portfolios and allocations across portfolios will not always be made on a pro-rata basis. The Investment Manager endeavors to allocate investment opportunities to client portfolios in a fair and equitable manner over time. The Investment Manager’s Chief Compliance Officer reviews all trade allocations in order to ensure that accounts are treated fairly. Additionally, a written policy governs the allocation of investment capacity and a formal allocation report is submitted to the Chief Compliance Officer.

(a)(3)

Description of Compensation

Each of the Portfolio Managers identified in response to Item 8(a)(1) above receives compensation that includes a fixed base salary, a discretionary bonus and an allocation of the firm’s net profits based on such Portfolio Manager’s percentage ownership interest in the firm.  Each Portfolio Manager's fixed base salary is based on the level of their position.  Bonuses, which are awarded in the form of cash, are variable and are determined based on an evaluation of a number of factors, including, primarily, the individual’s performance during the year, the firm’s profitability and financial condition and market compensation levels.  Bonuses are not determined formulaically with reference to any specific performance benchmarks or criteria and no single factor in determining bonuses is necessarily weighted more than any other factor; rather they are determined based on a general evaluation of the above and other factors determined to be appropriate by the firm’s Co-Chief Executive Officers.  The information provided in response to this Item 8(a)(3) is provided as of December 31, 2020.

(a)(4)

Ownership of Securities

As of January 31, 2021 the portfolio managers owned Interests (either directly or indirectly) of the Fund as follows:

Jonathan Bishop	None
Anne Casscells	$100,001-500,000
James Gibbons	$500,001-1,000,000
Michael Klein	$50,001-100,000

(b) Not applicable

Item 9. Purchases of Equity Securities by Closed-End Management Company and Affiliated Purchasers.

Not applicable as Interests of the Fund are not registered pursuant to Section 12 of the Exchange Act.

Item 10. Submission of Matters to a Vote of Security Holders.

There have been no material changes to the procedures by which shareholders may recommend nominees to the registrant’s board of directors since the registrant’s last proxy solicitation.

Item 11. Controls and Procedures.

(a) The certifying officers, whose certifications are included herewith, have evaluated the registrant’s disclosure controls and procedures within 90 days of the filing date of this report. In their opinion, based on their evaluation, the registrant’s disclosure controls and procedures are adequately designed, and are operating effectively to ensure, that information required to be disclosed by the registrant in the reports it files or submits under the Securities Exchange Act of 1934 is recorded, processed, summarized and reported within the time periods specified in the Securities and Exchange Commission’s rules and forms.

(b) There were no significant changes in the registrant’s internal control over financial reporting that occurred during the registrant’s last fiscal half-year that have materially affected, or are reasonably likely to materially affect, the registrant’s internal control over financial reporting.

Items 12. Disclosure of Securities Lending Activities for Closed-End Management Investment Companies.

Not applicable as the Fund does not engage in securities lending activities.

Items 13. Exhibits.

(a)(1) Code of Ethics attached hereto.

(a)(2) A separate certification for the principal executive officer and the principal financial officer of the registrant as required by Rule 30a-2(a) under the Investment Company Act of 1940, as amended (17 CFR 270.30a-2(a)), are filed herewith.

(b) Officer certifications as required by Rule 30a-2(b) under the Investment Company Act of 1940, as amended (17 CFR 270.30a-2(b)) also accompany this filing as an Exhibit.

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

(Registrant)	Aetos Multi-Strategy Arbitrage Fund, LLC
By (Signature and Title)*	/s/ Michael F. Klein
	Michael F. Klein, President
Date: 04/01/21

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

By (Signature and Title)*	/s/ Michael F. Klein
	Michael F. Klein, President
Date: 04/01/21
By (Signature and Title)*	/s/ Scott D. Sawyer
	Scott D. Sawyer, Treasurer
Date: 04/01/21

* Print the name and title of each signing officer under his or her signature.

EX-99.CODEETH

III.       CODES OF ETHICS

AETOS MULTI-STRATEGY ARBITRAGE FUND, LLC
AETOS DISTRESSED INVESTMENT STRATEGIES FUND, LLC
AETOS LONG/SHORT STRATEGIES FUND, LLC
and
AETOS ALTERNATIVES MANAGEMENT, LP

Code of Ethics Pursuant to Rule 17j-1 of the Investment Company Act

I.                     Introduction

Aetos Multi-Strategy Arbitrage Fund, LLC, Aetos Distressed Investment Strategies Fund, LLC and Aetos Long/Short Strategies Fund, LLC (each, a "Fund" and, collectively, the "Funds") and Aetos Alternatives Management, LP (the "Adviser") recognize the importance of high ethical standards in the conduct of their business and require that this Code of Ethics (the "Code") be observed by each Access Person (defined below in Section III a.). All recipients of this Code are hereby directed to read it carefully, retain it for future reference and abide by the rules and policies set forth herein.

While compliance with the provisions of this Code is anticipated, Access Persons should be aware that in response to any violations, the Funds and the Adviser will take whatever action is deemed appropriate under the circumstances including, but not necessarily limited to, dismissal of such Access Person. Technical compliance with the procedures of this Code will not automatically insulate from scrutiny trades that show a pattern of abuse of an individual's fiduciary duties^[1] to the Funds.

II.                   Purpose

This Code has been adopted by the Funds and the Adviser pursuant to Rule 17j-1 under the Investment Company Act of 1940, as amended (the "1940 Act"). Rule 17j-1 generally prohibits fraudulent or manipulative practices with respect to purchases or sales of securities held or to be acquired by investment companies, if effected by persons associated with such companies. The purpose of this Code is to provide regulations and procedures consistent with the 1940 Act and Rule 17j-1.

The basic tenets of Rule 17j-1 are as follows:

It is unlawful for any Access Person, principal underwriter for a Fund or affiliated person^[2] of a principal underwriter for a Fund, in connection with the purchase or sale, directly or indirectly, by such person of a Security Held or to Be Acquired (as defined below in Section III m.) by a Fund:

a. to employ any device, scheme or artifice to defraud the Funds,

b. to make to the Funds any untrue statement of a material fact or to omit to state to the Funds a material fact necessary in order to make the statements made, in light of the circumstances under which they are made, not misleading, or

¹ A fiduciary duty is a duty to act for someone else's (i.e., our Fund shareholders) benefit, while subordinating one's personal interests to that of the other person. It is the highest standard of duty imposed by law.

² Affiliated person as such term is defined in Section 2(a)(3) of the 1940 Act.

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c. to engage in any act, practice, or course of business that operates or would operate as a fraud or deceit upon the Funds, or to engage in any manipulative practice with respect to the Funds.

III.                 Definitions

a. "Access Person," means any manager, officer, trustee, general partner, or Advisory Person of the Funds or the Adviser.

b. "Advisory Person" means (1) any director, officer, general partner or employee of the Funds or the Adviser, or of any company in a control relationship to the Funds or the Adviser, who, in connection with his or her regular functions or duties, makes, participates in, or obtains information regarding the purchase or sale of a Security by the Funds, or whose functions relate to the making of any recommendations with respect to such purchases or sales and (2) any natural person in a control relationship to the Funds or the Adviser who obtains information concerning recommendations made to the Funds or the Adviser with regard to the purchase or sale of a Security by the Funds.

c. "Independent Manager" is anyone who sits on the Board of Managers of the Funds (the "Board of Managers") and who has no relationship with the Funds other than that of serving as a member of the Board of Managers, and who is not otherwise classifiable as an Access Person or an Advisory Person; and who is not an "interested person" of the Funds within the meaning of Section 2(a)(19) of the 1940 Act.

d. "Investment Personnel" means (1) any employee of the Funds or the Adviser (or of any company in a control relationship to the Funds or the Adviser) who, in connection with his or her regular functions or duties, makes or participates in making recommendations regarding the purchase or sale of securities by the Funds and (2) any natural person who controls the Funds or the Adviser and who obtains information concerning recommendations made to the Funds regarding the purchase or sale of securities by the Funds.

e. A Security is "being considered for purchase or sale" when a recommendation to purchase or sell a Security has been made and communicated or, with respect to the person making the recommendation, when such person considers making such a recommendation or when there is any outstanding order to purchase or sell that security.

f. "Control" means the power to exercise a controlling influence over the management or policies of the Funds or the Adviser. See Section 2(a)(9) of the 1940 Act.

g. "Beneficial Ownership" means ownership of securities or securities accounts by or for the benefit of a person, or such person's "family member," including any account in which the person or family member of that person holds a direct or indirect beneficial interest, retains discretionary investment authority or exercises a power of attorney. The term "family member" means any person's spouse, child or other relative, whether related by blood, marriage, or otherwise, who either resides with, is financially dependent upon, or whose investments are controlled by that person. The term also includes any unrelated individual whose investments are controlled and whose financial support is materially contributed to by that person, such as a "significant other."

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h. "Security" shall have the meaning set forth in Section 2(a)(36) of the 1940 Act, except that it shall not include shares of registered open-end investment companies, securities issued by the Government of the United States, short term debt securities which are "government securities" within the meaning of Section 2(a)(16) of the 1940 Act, bankers' acceptances, bank certificates of deposit, commercial paper and high quality short-term debt instruments, including repurchase agreements. For purposes of this Code, “Security” shall include cryptocurrencies and other similar digital assets other than those specifically excepted by the Compliance Officer.

i. "Security Held or to Be Acquired" shall mean (i) any Security which, within the most recent 15 days, is or has been held by the Fund or is being or has been considered by the Fund or the Adviser for purchase by the Fund, and (ii) any option to purchase or sell (and any security convertible into or exchangeable for) a Security.

j. "Initial Public Offering" means an offering of securities registered under the Securities Act of 1933, as amended, the issuer of which, immediately before the registration, was not subject to the reporting requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, as amended.

k. "Limited Offering" means an offering that is exempt from registration under the Securities Act of 1933, as amended, pursuant to Section 4(2) or Section 4(5) or pursuant to Rules 504, 505 or 506 under the Securities Act of 1933, as amended.

l. "Purchase or Sale of a Security" includes, among other things, the writing of an option to purchase or sell a Security.

m. "Security Held or to be Acquired" by a Fund means any Security which, within the most recent 15 days, (1) is being or has been held by such Fund, or (2) is being or has been considered by such Fund or the Adviser for purchase by such Fund.

n. "Compliance Officer" shall mean, with respect to the Funds or the Adviser, the person appointed by the Board of Managers or management of the Adviser, as the case may be, to administer the Code and shall include other person(s) designated by the Compliance Officer to administer the Code.

o. "Access Person of an Affiliated Underwriter" shall mean any director, officer or general partner of an Affiliated Underwriter who, in the ordinary course of business, makes, participates in or obtains information regarding the purchase or sale of Securities by the Fund for which the principal underwriter acts, or whose functions or duties in the ordinary course of business relate to the making of any recommendation to the Fund regarding the purchase or sale of Securities.

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p. "Affiliated Underwriter" shall mean any principal underwriter of a Fund that (i) is an affiliated person, as such term is defined in Section 2(a)(3) of the 1940 Act, of the Fund or the Adviser or (ii) has an officer, director or general partner who serves as an officer, director or general partner of the Fund or the Adviser.

IV.                Exempted Transactions

The prohibitions of Section V of this Code shall not apply to:

a. Purchases or sales effected in any account over which the Access Person has no direct or indirect influence or control.

b. Open-end mutual funds, including money market funds purchased or sold directly through the Funds or its transfer agent.

c. Purchases that are made by reinvesting cash dividends pursuant to an automatic dividend or distribution reinvestment program or employee stock option plan (this exception does not apply to optional cash purchases).

d. U.S. Government Securities purchased directly from the U.S. Government.

e. Bank certificates of deposits purchased directly from a bank.

f. Purchases effected upon the exercise of rights issued by an issuer pro rata to all holders of a class of its securities, to the extent such rights were acquired from such issuer, and sales of such rights so acquired.

g. Purchases or sales which are non-volitional on the part of either the Access Person, the Funds or the Adviser.

V.                  Compliance Procedures

A. General Prohibition:

No Access Person shall purchase or sell directly or indirectly, any Security in which he or she has, or by reason of such transaction acquires, any Beneficial Ownership and which he or she knows or should have known at the time of such purchase or sale;

1. is being considered for purchase or sale by the Funds, or

2. is being purchased or sold by the Funds.

B. Conflicts of Interest:

Each Access Person has the duty to disclose to the Funds and the Adviser, as the case may be, any interest whatsoever that he or she may have in any firm, corporation or business unit with which he or she is called upon to deal as part of his or her assigned duties with the Funds or the Adviser, or any other activity that the Access Person reasonably believes presents a potential conflict of interest. This disclosure should be timely so that the Funds or the Adviser may take such action concerning the conflict as deemed appropriate by the Compliance Officer or the General Counsel of the Adviser.

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C. Gifts:

Access Persons may not accept any fee, commission, gift, or services, other than de minimis gifts, from any persons or entities doing business with or on behalf of the Funds.

D. Service as a Board Member:

If one or more Funds invest in Securities other than interests in private investment funds, no Investment Personnel may serve on the board of a publicly traded company unless prior authorization is obtained from the Compliance Officer based on a determination that (1) the business of such company does not conflict with the interests of the Funds, (2) service would be consistent with the best interests of the Funds and its shareholders, and (3) service is not prohibited by law. If such service is authorized, procedures will then be put in place to isolate such Investment Personnel serving as managers of outside entities from those making investment decisions on behalf of the Funds.

Advance notice should be given so that the Funds or the Adviser may take such action concerning the conflict as deemed appropriate by the Compliance Officer.

E. Initial Public Offerings and Limited Offerings:

Investment Personnel must obtain prior approval from the Compliance Officer before directly or indirectly acquiring Beneficial Ownership in any securities in an Initial Public Offering or in a Limited Offering. Those Investment Personnel who have obtained prior approval and made an investment in an Initial Public Offering or a Limited Offering must disclose that investment to the Compliance Officer when such Investment Personnel play a part in any subsequent consideration of an investment in the issuer by a Fund. Under such circumstances, the decision by a Fund to purchase securities of the issuer of the Initial Public Offering or the Limited Offering must be subject to independent review by the Compliance Officer or Investment Personnel with no personal interest in the issuer.

F. Purchases or Sales by Investment Personnel:

No Investment Personnel may purchase an interest in a private investment fund without the prior approval of the Compliance Officer. If one or more Funds invest in Securities other than interests in private investment funds, no Investment Personnel may execute a personal Securities transaction within seven (7) calendar days before and after a Fund trades in that Security.

G. Short-Term Trading Profits:

If one or more Funds invest in Securities other than interests in private investment funds, Investment Personnel may not profit from the purchase and sale, or sale and purchase, of the same or equivalent Securities within 60 calendar days.

VI.                Violations and Sanctions

All Access Persons must report any violations or potentials violations of this Code promptly to the Compliance Officer.

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If the Compliance Officer discovers that an Access Person has violated any provision of the Code, the Adviser may impose such sanctions as he or she deems appropriate, including, but not limited to, a letter of censure, suspension with or without pay, or termination of employment. Any such violation shall be reported to the Board of Managers at the next meeting of the Board of Managers occurring after the Compliance Officer becomes aware of the violation.

Any profits realized on personal transactions in violation of the Code must be disgorged in a manner directed by the Adviser.

VII.               Reporting and Monitoring

A. The Compliance Officer shall monitor the personal trading activity of all Access Persons pursuant to the procedures established under this Code. The Adviser uses Compliance Science, a web-based compliance tool through which employees make all required compliance disclosures and certifications and through which all personal trading approvals and related record-keeping are processed and maintained, for reporting and monitoring. Each employee has a unique log-in that will allow them to access Compliance Science. New hires will receive an e-mail upon beginning their employment with instructions on registering on Compliance Science. Any questions regarding Compliance Science should be directed to the Compliance Officer.

B. Each Access Person, except the Independent Managers³, shall submit to the Compliance Officer through Compliance Science:

(i) Initial Holdings Reports. No later than 10 days after the person becomes an Access Person, the following information (which must be current as of a date no more than 30 days prior to the date the person becomes an Access Person):

(a) The title, number of shares and principal amount of each Security in which the Access Person had any Beneficial Ownership when the person became an Access Person;

(b) The name of any broker, dealer or bank with whom the Access Person maintained an account in which any securities were held for the direct or indirect benefit of the Access Person as of the date the person became an Access Person; and

(c) The date that the report is submitted by the Access Person.

(ii) Quarterly Transaction Reports. No later than 30 days after the end of a calendar quarter, the following information:

(a) With respect to any transaction during the quarter in a Security in which the Access Person had any Beneficial Ownership:

³ Independent Managers may be required to file a Quarterly Transaction Report — see Section VII C. below.

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(1) The date of the transaction, the title, the interest rate and maturity date (if applicable), the number of shares and the principal amount of each Security involved;

(2) The nature of the transaction (i.e., purchase, sale or any other type of acquisition or disposition);

(3) The price of the Security at which the transaction was effected;

(4) The name of the broker, dealer or bank with or through which the transaction was effect; and

(5) The date that the report is submitted by the Access Person.

(b) With respect to any account established by the Access Person in which any securities were held during the quarter for the direct or indirect benefit of the Access Person:

(1) The name of the broker, dealer or bank with whom the Access Person established the account;

(2) The date the account was established; and

(3) The date that the report is submitted by the Access Person.

(iii) Annual Holdings Reports. Annually, the following information (which information must be current as of a date no more than 45 days before the report is submitted):

(a) The title, number of shares and principal amount of each Security in which the Access Person had any Beneficial Ownership;

(b) The name of any broker, dealer or bank with whom the Access Person maintains an account in which any securities are held for the direct or indirect benefit of the Access Person; and

(c) The date that the report is submitted by the Access Person.

The reports noted above in this Section VII B are not required with respect to any Security held in an account referred to in Section IV(a) of this Code.

C. An Independent Manager need only file a Quarterly Transaction Report if he or she, at the time of a transaction, knew, or in the ordinary course of fulfilling his or her official duties as a member of the Board of Managers, should have known that during the 15 day period immediately preceding or following the date of the transaction in a Security by the Independent Manager the Security was purchased or sold by a Fund or was considered for purchase or sale by a Fund.

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D. Any Access Person of an Affiliated Underwriter shall also submit the reports described in Section VII B. of this Code. The Compliance Officer will notify any Access Person of an Affiliated Underwriter of his or her obligation to file the reports described in Section VII B. of this Code.

E. Each Access Person shall annually certify through Compliance Science that he or she has received, read and understood the Code and that he or she is subject to and has complied with each of the Code's provisions applicable to such person. Each newly hired Access Person shall certify through Compliance Science that he or she has received, read and understood the Code. Upon any material change to this Code, each Access Person shall certify through Compliance Science that he or she has received, read and understood the amended Code and that he or she is subject to and has complied with each of the Code's provisions applicable to such person.

F. The Compliance Officer shall prepare annually a written report for the Board of Managers which (1) describes any issues arising under the Code since the last report to the Board of Managers, including, but not limited to, information about material violations of the Code and sanctions imposed in response thereto and (2) certifies that the Funds, the Adviser and any Affiliated Underwriter have adopted procedures reasonably necessary to prevent Access Persons or Access Persons of an Affiliated Underwriter from violating the Code.

G. All reports furnished pursuant to this Code will be maintained on a confidential basis and will be reasonably secured to prevent access to such records by unauthorized personnel.

H. An Access Person need not make a Quarterly Transaction Report under Section VII B(ii) if all of the information required in such report would duplicate information (1) contained in broker trade confirmations or account statements received by a Fund or the Adviser with respect to the Access Person in the time period required by Section VII B(ii) or (2) required to be recorded under Rule 204-2(a)(12) under the Investment Advisers Act of 1940, as amended.

VIII.             Recordkeeping

The Funds and the Adviser will maintain the following records at their principal place of business by such means permissible under the conditions described in Rule 31a-2 of the 1940 Act and Rule 204-2 of the Advisers Act (or under no-action letters or interpretations under these rules) and make these records available to the SEC or any representative of the SEC at any time and from time to time for reasonable periodic, special or other examination:

(a) A copy of this Code in an easily accessible place;

(b) A record of any violation of the Code, and any action taken as a result of the violation, in an easily accessible place for at least five years after the end of the fiscal year in which the violation occurs;

(c) A copy of each report made by an Access Person for at least five years after the end of the fiscal year in which the report is made, the first two years in an easily accessible place;

(d) A record of all persons, currently or within the past five years, who are or were required to make reports as required by this Code, or who are or were responsible for reviewing these reports, in an easily accessible place;

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(e) A copy of each report required by Section VII E of the Code for at least five years after the end of the fiscal year in which the report is made, the first two years in an easily accessible place; and

(f) A record of any decision, and the reasons supporting the decision, to approve the acquisition by Investment Personnel of securities under Section V E of the Code for at least five years after the end of the fiscal year in which the approval is granted.

IX.                 Amendments

A. Any material change to this Code must be approved by the Board of Managers, including a majority of the Independent Managers, within six (6) months after such material change has been adopted by the Adviser. Further:

i. Any approval of a material change to this Code by the Board of Managers must be based on a determination that the amended Code contains provisions reasonably necessary to prevent Access Persons from engaging in any conduct prohibited by Rule 17j-1 under the 1940 Act; and

ii. Prior to the approval of any amendments to this Code, the Fund or Adviser will provide the Board of Managers with a certification that it has adopted procedures reasonably necessary to prevent Access Persons from violating this Code.

B. Any Affiliated Underwriter must adopt a written code of ethics that contains provisions reasonably necessary to comply with Rule 17j-1 of the 1940 Act. Any material change to such Affiliated Underwriter's code of ethics must be approved by the Board of Managers in the manner prescribed under Section IX A. of this Code.

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EX-99.CERT

CERTIFICATION

Pursuant to Section 302

of the Sarbanes-Oxley Act of 2002

I, Michael F. Klein, certify that:

1. I have reviewed this report on Form N-CSR of Aetos Multi-Strategy Arbitrage Fund, LLC;

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;

4. The registrant's other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940)for the registrant and have:

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

(c) Evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and

(d) Disclosed in this report any change in the registrant's internal control over financial reporting that occurred during the registrant's most recent fiscal half-year (the registrant's second fiscal half-year in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the registrant's internal control over financial reporting; and

5. The registrant's other certifying officer(s) and I have disclosed to the registrant's auditors and the audit committee of the registrant's board of directors (or persons performing the equivalent functions):

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant's ability to record, process, summarize, and report financial information; and

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant's internal control over financial reporting.

Date: April 1, 2021

/s/ Michael F. Klein     
Michael F. Klein
President

CERTIFICATION

Pursuant to Section 302

of the Sarbanes-Oxley Act of 2002

I, Scott D. Sawyer, certify that:

1. I have reviewed this report on Form N-CSR of Aetos Multi-Strategy Arbitrage Fund, LLC;

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;

4. The registrant's other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940)for the registrant and have:

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

(c) Evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and

(d) Disclosed in this report any change in the registrant's internal control over financial reporting that occurred during the registrant's most recent fiscal half-year (the registrant's second fiscal half-year in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the registrant's internal control over financial reporting; and

5. The registrant's other certifying officer(s) and I have disclosed to the registrant's auditors and the audit committee of the registrant's board of directors (or persons performing the equivalent functions):

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant's ability to record, process, summarize, and report financial information; and

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant's internal control over financial reporting.

Date: April 1, 2021

/s/ Scott D. Sawyer   
Scott D. Sawyer
Treasurer

EX-99.906CERT

CERTIFICATION

Pursuant to Section 906

of the Sarbanes-Oxley Act of 2002

The undersigned, the President of Aetos Multi-Strategy Arbitrage Fund, LLC (the "Fund"), with respect to the Fund’s Form N-CSR for the period ended January 31, 2021 as filed with the Securities and Exchange Commission, hereby certifies, pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002, that, to the best of my knowledge:

1.        such Form N-CSR fully complies with the requirements of section 13(a) or 15(d) of the Securities Exchange Act of 1934; and

2.        the information contained in such Form N-CSR fairly presents, in all material respects, the financial condition and results of operations of the Fund.

Dated: April 1, 2021

/s/ Michael F. Klein              

Michael F. Klein

CERTIFICATION

Pursuant to Section 906

of the Sarbanes-Oxley Act of 2002

The undersigned, the Treasurer of Aetos Multi-Strategy Arbitrage Fund, LLC (the "Fund"), with respect to the Fund’s Form N-CSR for the period ended January 31, 2021 as filed with the Securities and Exchange Commission, hereby certifies, pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002, that, to the best of my knowledge:

1.        such Form N-CSR fully complies with the requirements of section 13(a) or 15(d) of the Securities Exchange Act of 1934; and

2.        the information contained in such Form N-CSR fairly presents, in all material respects, the financial condition and results of operations of the Fund.

Dated: April 1, 2021

/s/ Scott D. Sawyer               

Scott D. Sawyer