AML Attestation

You hereby confirm the following in accordance with the standards of a prudent professional and the applicable laws and regulations:

1. We maintain an Anti Money Laundering & Counter Terrorist Financing (“AML/CTF”) policy and program and an on-going training program for all applicable employees. We have identified an AML Officer responsible for overseeing the implementation of the program. We have implemented related procedures and controls including a procedure to identify, investigate and file suspicious activity reports;

2. We perform the identification and verification of the identity of our customers, beneficial owners, and control persons;

3. We perform enhanced due diligence on higher risk customers and their beneficial owners, where applicable, including politically exposed persons and, where a relationship is established with countries or territories which do not or insufficiently apply AML-CTF measures;

4. We perform on-going monitoring of the customer relationship to maintain due diligence information including detection of unusual transactions which are not consistent with the expected business activity;

5. We perform sanctions screening prior to the account opening and on an on-going basis of the underlying customers, their beneficial owners, and control persons where applicable. We perform sanctions screening against the listings of the US Department of Treasury, Office of Foreign Asset Control (“OFAC”);

6. We retain customer due diligence documentation during a period of five years following the end of the business relationship; and

7. We do not enter into business relationships with shell banks or accept shell banks as underlying customers or beneficial owners.