WestinPay - AML-KYC

1. Company Policy

Anti-Money Laundering and Anti-Terrorism (Prevention) Law, Anti-Money Laundering and Anti-Terrorism (Prevention) Law Guidelines, Anti-Money Laundering and Terrorism Financing (AML /CFT) Guidelines, FATF recommendations and implementation regulations.

In general, the money laundering process consists of three "stages":

Placement: The introduction of illegally obtained money or other valuables into financial or non-financial institutions.

Layering: The separation of proceeds from criminal activities from their sources using complex layers of financial transactions. These layers are designed to prevent audit tracking, hide the source of funds and provide anonymity.

Integration: The placement of laundered proceeds back into the economy in such a way that they re-enter the financial system as seemingly legitimate funds.

These "stages" are not static and overlap widely. Financial institutions can be misused at any point in the money laundering process.

1. Company Policy

In general, the money laundering process consists of three "stages":

Placement: The introduction of illegally obtained money or other valuables into financial or non-financial institutions.

Integration: The placement of laundered proceeds back into the economy in such a way that they re-enter the financial system as seemingly legitimate funds.

These "stages" are not static and overlap widely. Financial institutions can be misused at any point in the money laundering process.

WESTINGPAY is committed to the highest standards of anti-money laundering (AML) compliance and requires management and employees to comply with these standards in order to prevent our products and services from being used for money laundering purposes. WESTINGPAY LTD will constantly review its Anti-Money Laundering strategies, goals and objectives and maintain an effective Anti-Money Laundering program for the Company's business that reflects best practices for a diversified, global financial company. Adherence to WESTINGPAY Ltd's Anti-Money Laundering Program is the responsibility of all employees. The program includes customer screening and monitoring requirements, “know your customer” policies (including the obligation to identify usufruct holders), Embargo policies, record-keeping requirements, reporting suspicious situations in accordance with relevant laws, and trainings., is committed to the highest standards of anti-money laundering (AML) compliance and requires management and employees to comply with these standards in order to prevent our products and services from being used for money laundering purposes. WESTINGPAY LTD will constantly review its Anti-Money Laundering strategies, goals and objectives and maintain an effective Anti-Money Laundering program for the Company's business that reflects best practices for a diversified, global financial company. Adherence to WESTINGPAY Ltd's Anti-Money Laundering Program is the responsibility of all employees. The program includes customer screening and monitoring requirements, “know your customer” policies (including the obligation to identify usufruct holders), Embargo policies, record-keeping requirements, reporting suspicious situations in accordance with relevant laws, and trainings.

2. AML Compliance Person

The Company will provide the Authorities with the contact information of the AML Compliance Person, including: (1) name; (2) title; (3) mailing address; (4) email address; (5) phone number; and (6) fax number. The company will inform the Institution immediately in case of any changes in this information and will review and update this information within 14 working days from the end of each calendar year if necessary. The annual review of the FCS information will be carried out by the CO and will be completed with the provision of all necessary updates no later than 17 business days following the end of each calendar year. In addition, in case of any change in the information, CO will update the information immediately, but in any case not exceeding 30 days following the change.

3. Preventive Measures

This section underlines the following: "Countries should ensure that the Anti-Money Laundering and Terrorism (Prevention) Act does not impede the implementation of FATF Recommendations.

Financial institutions should be prohibited from maintaining accounts belonging to anonymous or obviously fictitious names.

Financial institutions should be required to take customer due diligence (CDD) measures in the following cases:

(i) to establish business relations;

(ii) (i) to carry out occasional transactions above the current specified threshold (Dec. 15,000 USD/EUR);

or (ii) Bank transfers in the conditions covered by the Explanatory Note to Recommendation 16, which are;

(iii) there is a suspicion of money laundering or financing of terrorism;

or (iv) if the financial institution has doubts about the accuracy or adequacy of the customer identity data obtained in advance. The principle that financial institutions should make CDD should be regulated by law. Each country can determine how to implement certain CDD obligations by law or by enforceable means. The CDD measures to be taken are as follows:

(a) Identification of the customer and verification of the customer's identity using reliable, independently sourced documents, data or information.

(c) To understand the purpose and intended nature of the business relationship and to obtain information about it to the extent appropriate.

(d) To conduct continuous due diligence throughout the business relationship and to examine the transactions carried out throughout this relationship in order to ensure that the transactions carried out are consistent with the institution's knowledge of the customer, its business and its risk profile, including, if necessary, the source of funds.

(i) above the applicable specified threshold (US$15,000/EUR); or (ii) bank transfers in the conditions covered by the Explanatory Note to Recommendation 16;

(iii) there is a suspicion of money laundering or terrorist financing; or (iv) if the financial institution has doubts about the accuracy or adequacy of previously obtained customer identity data. The principle that financial institutions should make CDD should be regulated by law. Each country can determine how to implement certain CDD obligations by law or by enforceable means.

The CDD measures to be taken are as follows:

(a) Identification of the customer and verification of the customer's identity using reliable, independently sourced documents, data or information.

(b) Identifying the actual beneficiary in such a way as to ensure that the financial institution is satisfied that it knows who the usufruct holder is, and taking reasonable measures to verify the identity of the actual beneficiary. For legal entities and regulations, this should also include the understanding of ownership of financial institutions Financial institutions should be required to implement each of the CDD measures from (a) to (d) above, but determine the scope of these measures using a risk-based approach ( RBA) in accordance with this Recommendation and the Explanatory Notes to Recommendation 1. Financial institutions should be obliged to verify the identity of the customer and the usufruct holder before or during establishing a business relationship or conducting transactions for occasional customers. Dec. Countries may allow financial institutions to complete verification as soon as possible after the establishment of the relationship, if the risks of money laundering and terrorist financing are effectively managed and it is necessary to ensure that the normal flow of business is not interrupted.

In case the financial institution is unable to comply with the applicable requirements under paragraphs (a) to (d) above (subject to appropriate modification of the scope of the measures according to a risk-based approach), it should be requested not to open the account. , to initiate a business relationship or perform a transaction; or if it is necessary to terminate a business relationship; should consider notifying the customer of a suspicious transaction. These requirements should apply to all new customers, but financial institutions should also apply this advice to existing customers on the basis of materiality and risk, and conduct due diligence on such existing relationships at appropriate times.

Financial institutions should be required to keep all necessary records of both domestic and international transactions for at least seven years in order to ensure that they can quickly adapt to information requests from the competent authorities. Such records must be sufficient to allow the reconstruction of individual transactions (including the amounts and types of currencies involved, if any) in order to provide evidence for the prosecution of a criminal activity, if necessary. All records of financial institutions obtained through CDD measures (for example, copies or records of official identification documents, such as passports, ID cards, driver's licenses, or similar documents), account files and business correspondence, including the results of any analysis performed (for example, investigations to determine the background and purpose of complex, unusually large transactions), for at least seven years after the termination of the business relationship or after the date of the transaction, which occurred Dec. Financial institutions should be required by law to keep records of transactions and information obtained through CDD measures. CDD information and transaction records should be submitted to the local competent authorities upon appropriate authorization.

It should be made necessary for financial institutions to apply advanced due diligence measures for business relations and transactions with natural and legal persons and financial institutions in the countries requested by the FATF. The type of advanced due diligence measures applied should be effective and proportionate to the risks. Countries should be able to implement appropriate countermeasures when requested by the FATF. Countries should also be able to implement countermeasures independently of any calls from the FATF. Such countermeasures should be effective and proportionate to the risks. The measures mentioned above are also included in the FATF Recommendations (February 2012) of the 22nd INTERNATIONAL STANDARDS ON COMBATING Money Laundering and THE FINANCING OF TERRORISM AND THE FINANCING OF BROADCASTING. according to the section, it can also be applied to our sector.

4. Checking the Lists of the Foreign Assets Control Office

Before the final approval of a client and on an ongoing basis, CO will check to make sure that a client does not appear on the SDN list or engage in transactions prohibited by the economic sanctions and embargoes administered and imposed by OFAC. (See the OFAC website for the SDN list and the list of current sanctions and embargoes). Since the SDN list and the economic sanctions and embargo lists are updated frequently, we will consult them regularly and subscribe to receive the current updates as they occur. Regarding the SDN list, we can also access this list Decently through various software programs, including FINRA's OFAC Search Tool, which scans names according to the SDN list to ensure speed and accuracy. The CO will also review the existing accounts according to the SDN list and the existing sanctions and embargo lists when they are updated, and document the review.

If we find that a client is on the SDN list or engaged in transactions prohibited by the economic sanctions and embargoes imposed by OFAC, we will reject the transaction and/or block the client's assets and block the assets and/or reject the transaction form to OFAC within 10 days. We will also immediately call the OFAC Hotline at (731) 108-3178. Our review will include the customer's corporate documents, accounts, transactions related to customers (including activities that pass through the company, such as cables).

5. Customer Identification Program

In addition to the information we are required to collect under the Ministry of Finance's Anti-Money Laundering and Prevention of Terrorist Financing Act No. 13 of October 2014, we have created, documented and maintained a written Customer Identification Program (CIP) in accordance with FINRA Rule 2010 (Commercial Honor Standards and Trade Principles) and Books and Records. We will collect certain customer credentials from each customer who gives us assets for administration, we will use risk-based measures to verify the identity of each customer who opens an account; record customer credentials and verification methods and results; To provide the necessary adequate CIP notification to customers, whose credentials we will search to verify their identity; and compare customer credentials with government-provided lists of suspected terrorists; after these lists are published by the government.

A. Required Customer Information

Before approving our services, CO will collect the following information for all customers for any person, organization or organization, if any:

(1) name;

(2) an address contact person (for a person) that will be a residence or workplace address, Army Post Office (APO) or Fleet Post Office (FPO) box number or the residence or workplace address of the next of kin (for a person without a residence or workplace address) or the main workplace, local office or other physical location (for a person other than an individual);

When adding money with debit cards in RUB currency below October 15,000, there is no need for photo verification of the card. 3DSecure verification is sufficient.

Withdrawals of up to $999 per day are possible for unverified accounts.

B. Customers Who Refuse to Provide Information

If a potential or existing customer refuses to provide the information described above when requested, or appears to have provided intentionally misleading information, our company will not provide our services and will consider closing any business with the customer after evaluating the relevant risks. In both cases, our AML Compliance Staff will be informed so that we can decide whether we need to report the situation to the Financial Intelligence Unit via a STR.

C. Verification of Information

Based on the risk and to the extent reasonable and practicable, we will ensure that we have a reasonable belief that we know the true identity of our customers by using risk-based procedures to verify and document the accuracy of the information we receive about our customers. customers. CO will analyze the information we have obtained to determine whether the information is sufficient to form a reasonable belief that we know the customer's true identity (for example, whether the information makes sense or contains inconsistencies).

We will verify the identity of the customer through the documents collected by us. We will use the documents to verify the customer's identity when the appropriate documents are available. In light of the increasing cases of identity fraud, we will support the use of documentary evidence, using the non-documentary methods described below, if necessary. If we are still unsure whether we know the real identity of the customer, we may also use non-document methods. When verifying the information, we will evaluate whether the identifying information we receive, such as the customer's name, street address, zip code, phone number (if any), date of birth and Social Security number, allows us to determine what we have. A reasonable belief that we know the true identity of the customer (for example, whether the information makes sense or contains inconsistencies).

The appropriate documents for verifying the identity of customers include the following:

- An expired, government-issued ID for a person that proves his nationality or place of residence and has a photo or similar security, such as a driver's license or passport, on it;

- For a person other than a natural person, documents indicating the existence of the organization, such as a certified articles of association, a business license issued by the state, a partnership agreement or a trust certificate.

We understand that we do not need to take any steps to determine whether the document provided to us by the customer for authentication has been validly issued, and we can rely on a government-issued ID to verify the customer's identity. However, if we find that the document shows an obvious form of fraud, we must take this factor into account when determining whether we can form a reasonable belief that we know the true identity of the customer.

We will use the following non-documentary methods to verify the identity:

- Independently verify the identity of the customer by comparing the information provided by the customer with information obtained from a consumer reporting organization, public database or others;

- Checking references with other financial institutions; or

- Obtaining the financial statement.

We will use non-documentary verification methods in the following cases:

(1) failure of the customer to submit an expired, government-issued identity document with a photo or other similar measure, together with;

(2) the company is not familiar with the documents submitted by the customer for identity verification;

(3) the absence of face-to-face contact between the client and the company; and

(4) the existence of other conditions that increase the risk of the company's inability to verify the customer's true identity by documentary means.

D. Record keeping

WESTINGPAY LTD follows established bookkeeping and documentation standards.

We will document our verification, including all identifying information provided by a customer, the methods used and the results of verification, as well as the resolution of all discrepancies identified during the verification process. We will keep records containing a description of any document that we trust to verify a customer's identity, indicating the type of document, any identification number contained in the document, the place where it was edited, and the date of issue and expiration date, if any. . Regarding undocumented verification, we will keep documents describing the methods and results of the measures we take to verify a customer's identity. We will also keep records containing the explanation of the solution of each significant discrepancy discovered when verifying the obtained credentials. We will keep the records related to the verification of the customer's identity for a period of seven years after the registration is made.

e. Comparison with Terrorist Lists Provided by the Government

When we receive notification that a federal government agency has published a list of known or suspected terrorists and has designated the list as a list for CIP purposes, within a reasonable period of time (or earlier, if required by another federal law or regulation or a federal directive issued in connection with a valid list) after entering into an agreement, consultation with federal functional regulators to determine whether a client is included in the list of known or suspected terrorists or terrorist organizations published by any federal government agency and designated as such by the Treasury. We will comply with all directives issued in connection with such lists.

We will continue to comply separately with the OFAC rules prohibiting transactions with certain foreign countries or their nationals.

F. Notification to Customers

As required by law, we will inform customers that the company has requested information from them in order to verify their identity. We will use the following method to notify customers: Email, Phone call or certified mail.

G. Relying on Another Financial Institution for Authentication

Under the following conditions, we may rely that some or all elements of our CIP will be fulfilled by another financial institution (including an affiliate company) in relation to any customer who enters into an agreement or similar business relationship with another financial institution. the institution that will provide or engage in services, agreements or other financial transactions:

- if the trust in question is reasonable under the circumstances;

- the other financial institution is subject to a rule that applies the requirements of the anti-money laundering compliance program and is regulated by a federal functional regulator; and

- in the event that another financial institution signs a contract with our company that requires it to certify to us annually that it has implemented a money laundering prevention program and will fulfill certain requirements related to customer identification (or that its representative will fulfill) the program.

6. High Risk Customer Due Diligence

We will receive the following information for our customers who we consider to be at a higher risk:

- the source of the fund;

- information of usufruct right holders;

- the profession or type of business of the client (or usufruct holder); financial statements;

- bank references;

- residence (where the client's business is organized);

- description of the customer's main trading area and whether international transactions are expected to be routine;

- description of business operations and expected trade volume.

We will also ensure that customer information remains accurate by following the established procedures of WESTINGPAY LTD.

7. Acceptable Fund Transfer Methods

Funds should be accepted only when they arrive through the bank.

The amount of funds received must match exactly the amount billed to the customer;

The funds must come from a reputable bank;

Special attention should be paid to the following issues and they should be clarified:

- Receipt of unexpected funds;

- Funds received from a country included in the non-compliant list;

- Fund receipts exceeding the amount billed to the customer;

- Receiving funds from unknown sources;

8. Monitoring Customers for Suspicious Activities

We will monitor account activity in terms of unusual size, volume, model or type of transaction, taking into account risk factors and danger signs that are appropriate for our business. Monitoring will be carried out by the following methods: CO will be responsible for this monitoring, will examine all the activities detected by our monitoring system, determine whether any additional steps are necessary, document and report when and how this monitoring is carried out, and forward suspicious activities October to the relevant authorities. WESTINGPAY LTD denies that politically influential people are in the service. WESTINGPAY LTD requires customers to provide documents regarding the source of funds in amounts exceeding 15,000 euros (customer's welfare).

We will perform the following activity reviews as detected by our monitoring system: Complete the Account Review. We will document our monitoring and reviews as follows: according to AML Compliance. The AML Compliance Staff or its designated person will conduct appropriate research and review relevant information from internal or third-party sources before submitting an STR application.

WESTINGPAY LTD prohibits and actively prevents money laundering and any activities that facilitate money laundering or the financing of terrorist or criminal activities by checking all clients on the following sanctions lists of OFAC (Office of Foreign Assets Control), United Kingdom (HMT) - sanctions regimes United Kingdom, European Union sanctions list and United Nations Security Council sanctions lists:

- OFAC list (Office of Foreign Assets Control)

- Consolidated List of the United Nations Security Council

- United Kingdom sanctions list

- Consolidated list of financial sanction targets in the UK

- European Union Consolidated Financial Sanctions List

A. Emergency Notification to Law Enforcement Agencies by Phone

In the case of violations that require urgent intervention, such as terrorist financing or ongoing money laundering schemes, we will immediately contact an appropriate law enforcement agency. When we report this kind of activity to the relevant security authority, we still need to apply for a SHIB in a timely manner.

Although we are not mandatory, we may contact the Financial Intelligence Unit in cases where we submit a STR that may require the immediate attention of the Financial Intelligence Unit.

B. Red flags

Red flags that indicate possible money laundering or financing of terrorism include, but are not limited to, the following:

Customers - Insufficient or Suspicious Information

* Provides unusual or suspicious identity documents that cannot be easily verified.

* Unwillingness to provide full information about the nature and purpose of the job, previous banking relationships, expected account movements, officers and directors, or place of employment.

* It is wrong, misleading or grossly wrong to refuse to specify a legitimate source for funding or information.

• The past is suspicious or differs from expectations based on business activities.

* A customer who has no apparent reason to use the company's service.

Efforts to Avoid Reporting and Record Keeping

* Being unwilling to provide the information required to file the reports or being unable to proceed with the processing.

* Attempts to convince an employee not to submit the necessary reports or keep the necessary records.

• "Structures" of deposits, withdrawals or purchases of monetary instruments below a certain amount to avoid reporting or record-keeping requirements.

* Unusual concern about the firm's compliance with the government's reporting requirements and the firm's AML policies.

Some Fund Transfer Activities

* Bank transfers to financial privacy havens or high-risk geographical areas/locations for no apparent business reason.

• Many small bank transfers or deposits made using checks and bank transfers. It was almost instantly withdrawn or the cable disconnected in a way inconsistent with the client's job or background. It could indicate a Ponzi scheme.

* Unexplained, repetitive, showing unusually large or unusual patterns, or telegraphic activity with no apparent business purpose.

Certain Deposit or Disposal of Physical Certificates

• The name of the physical certificate is different from the account.

• The physical certificate does not carry a restrictive description, but it must have such a description depending on the stock's history and/or share trading volume.

* The customer's explanation of how he received the certificate makes no sense or changes.

* The customer deposits the certificate with the request that the shares be registered in more than one account or that the shares be sold or their ownership be transferred in another way.

The Activity is Inconsistent with the Work

* Transaction patterns show a sudden change that is inconsistent with normal activities.

* Unusual money transfers between accounts or wage Decrees without any apparent business purpose.

* Maintains multiple accounts with no apparent business or other purpose, or maintains accounts on behalf of family members or corporate entities.

• He appears to be acting as an attorney for an unnamed client, but is reluctant to provide information.

Other Suspicious Customer Activities

* Unexplained high level of account activity combined with very low level of securities transactions.

• Money is deposited for the purchase of a long-term investment, and soon after comes the request to liquidate the position and transfer the proceeds out of the account.

* Subpoenas from law enforcement agencies.

• A large number of securities transactions in various jurisdictions.

* Purchase and sale of securities without purpose or under unusual circumstances (for example, cancellation at the customer's request).

* Paying by third-party check or money transfer without any visible connection with the customer.

* Payments made to third parties that have no apparent connection with the customer.

* The cost of transactions or fees (e.g. delivery fees, higher than necessary commissions, etc.) there is no concern with.

C. Responding to Red Flags and Suspicious Activity

An employee of the company will notify if he detects any signs of danger or any other suspicious activity. Under the direction of the AML Compliance Officer, the company will decide whether and how to investigate the matter further. This may include collecting additional information internally or from third-October sources, contacting the government, freezing the account and/or filling out a STR.

9. Suspicious Transactions and BSA Reporting

A. Filling of the STR

TEXT EXAMPLE: We will send a STR file to FIU for any transaction (including deposits and transfers) that we know of, suspect or suspect (individually or collectively) involving funds or assets of US$15,000 or more, performed or attempted by, within or through our company. you have reason to suspect:

(1) if the transaction involves funds obtained from illegal activity, or as part of a plan to violate or evade federal law or regulation, conceal or conceal funds or assets obtained from illegal activity, or any transaction under this law or regulation is intended or performed to avoid reporting requirements. federal law or regulation;

(2) the transaction, by way of configuration or otherwise, has been designed in such a way as to avoid any requirements of the IFSC regulations;

(3) the transaction has no commercial or apparent legal purpose, or is not the kind that the customer is normally expected to do, and after reviewing the background, possible purpose and other facts of the transaction, we know that there is no reasonable explanation for the transaction. the transaction; or

(4) if the transaction involves the use of the company to facilitate criminal activity.

We will also create a STR file and notify the relevant law enforcement agencies in cases of violations that require urgent intervention, such as terrorist financing or ongoing money laundering schemes.

We will report suspicious transactions by filling out a STR and collect and store supporting documents as required by IFSC and FIU regulations. We will apply for a CIB no later than 30 calendar days from the date of the first determination of the facts that constitute the basis for applying for a CIB. If no suspect is identified on the first detection date, we may delay the completion of the STR for an additional 30 calendar days until the suspect is identified, but in no case will the reporting be delayed by more than 60 calendar days after the first detection date. . The phrase "first detection" does not mean the moment when a transaction is highlighted for review. Upon the detection of any unusual activity that requires investigation, a review should be initiated immediately.

We will keep copies of any filed STR and the original or commercial registration equivalent of the supporting documents for five years from the date of submission of the STR. We will identify and maintain supporting documents and make such information available to the Financial Intelligence Division, other relevant law enforcement agencies, federal or state securities regulators.

Except as permitted by the IFSC and FIU regulations, we will not notify anyone involved in the transaction that the transaction has been notified. We understand that anyone who receives a subpoena or is required to disclose an STR or the information contained in the STR will provide any information that would disclose the disclosure of an STR, except in cases where disclosure is requested by the Financial Intelligence Unit or another appropriate law enforcement or regulatory agency. prepared or filed. We will notify the IFSC or the Financial Intelligence Unit or any such request and our response.

B. Foreign Exchange Transaction Reports

Our company has banned transactions involving foreign currency and has the following procedures to prevent such transactions: paying from other people's bank accounts or credit cards. If we find that such transactions are taking place, we will contact the Financial Intelligence Unit for currency transactions exceeding $ 10,000. In addition, if multiple transactions involving currency total more than US$10,000 and were made by or on behalf of the same person within any business day, we will treat them as a single transaction in order to determine whether you will apply for STR.

10. AML Record Keeping

A. Responsibility for Required AML Records and STR Filing

Our AML Compliance Staff and the person assigned by him will be responsible for ensuring that AML records are properly maintained and that the STR is recorded as required.

In addition, as part of our AML program, our company will create and maintain the Financial Intelligence Unit, IFSC and related documents related to customer identification and verification, as well as fund transfers. We will keep the Financial Intelligence Unit and the accompanying documents for at least seven years. We will store other documents in accordance with current laws and other record-keeping requirements.

B. SAR-SF Care and Privacy

We will keep the STR and supporting documents confidential. We will not provide information about a STR to anyone other than the Financial Intelligence Unit or other appropriate law enforcement or regulatory agency. We will reject any subpoena requests to the Financial Intelligence Unit or information that would disclose the preparation or filing of an STR, and we will immediately notify the Financial Intelligence Unit, FINCEN, of any such subpoena requests we receive. To prevent disclosure of STR files, we will separate STR files and copies of supporting documents from other company books and records. Our AML Compliance Person will handle all subpoenas or other requests to the Financial Intelligence Unit. We may share information about suspicious transactions with another financial institution.

C. Additional October Recordings

We will keep the original or microfilm or another copy or reproduction of each of the following:

- A record of every loan extension in excess of US$10,000, except for the loan extension secured by real estate interest. The record will contain the name and address, amount, nature or purpose and date of the person to whom the loan was opened,;

- A record of every advice, request or instruction received or given in connection with any transaction that resulted in (or was intended to result in) the transfer of currency or other monetary instruments, funds, checks, investment securities or other monetary instruments and was later canceled if such registration is normally made. loans of more than $10,000 to any person, account or place:

- A record of every recommendation, request or instruction given to another financial institution (including broker-dealers) or another person. Each document that authorizes signature or trade on each customer's account;

- Registration of any transfer or transfer of funds or currencies, checks, other monetary instruments, investment securities or loans exceeding US$ 10,000.

- A record of each transfer of currency, other monetary instruments, checks or investment securities received directly, not through a domestic financial institution, and each transfer of funds or loans exceeding US $ 10,000.

11. Educational Programs

We will develop continuous employee training under the leadership of the AML Compliance Officer and senior management. Our trainings will take place at least once a year. It will be created according to the size, customer base and resources of our office and will be updated as necessary to reflect new developments in the law.

As a minimum, our training will include: (1) how to detect danger signs and money laundering signs that occur during the duties of employees; (2) what to do after determining the risk (including how, when and to whom to transmit unusual customer activities or other danger signs for analysis and, where appropriate, to notify the Financial Intelligence Unit); (3) what are the roles of employees; the firm's compliance efforts and how to implement them, (4) the firm's record retention policy, and (5) the disciplinary consequences of non-compliance with the FISC (including civil and criminal penalties).

We will develop the training in our company or we will make a contract for it. The delivery of the training may include training brochures, videos, intranet systems, face-to-face lessons and explanatory notes. We will keep records showing the people who received education, the dates of education and the subject of the education they received.

We will review our operations to October to see if certain employees need special additional training, such as compliance, margin and corporate security. Our written procedures will be updated to reflect such changes.

12. Confidential Notification of AML Incompatibility

If the violations do not cover the AML Compliance Personnel, the employees will immediately report any possible violations related to the company's AML compliance program to the AML Compliance Personnel, in which case the employee will report to the CO. Such reports will be confidential and the employee will not experience any victimization. retaliation for doing these things.

13. Additional Risk Areas October

The firm has examined all areas of its business to identify possible money laundering risks that do not fall within the scope of the procedures described above.

14. Senior Manager Approval

Senior management has approved this AML compliance program in writing as reasonably designed to ensure and monitor our company's continued compliance with the requirements of the BSA and the implementing regulations under it.

Note: This Compliance Manual must be strictly followed by all Employees. Failure of any Employee to comply with this Compliance Manual will result in disciplinary proceedings. There are no exceptions in this Compliance Manual without the prior written approval of the Compliance Officer. Any questions, comments or concerns related to the Company's anti-money laundering policies, procedures and controls should be forwarded to the Compliance Officer.