AAAFx Anti-Money Laundering Policy

Introduction

Hellenic Capital Markets regulation rules contain specified requirements related to anti-money laundering which must be met by Brokers. AAAFX hereby agrees to perform the following specified requirements in order to satisfy certain regulatory obligations. AAAFX only assumes liability for the responsibilities that are outlined herein. The procedures outlined in this document extend beyond the AML CIP requirements; however, AAAFX shall only assume liability to regulators for the performance of CIP/KYC requirements as they pertain to Hellenic Capital Markets Rule 2-9.

(i) Customer Identification Program (CIP)

To aid the government’s fight against the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain and record information that identifies each person who opens an account at AAAFX. Accordingly, in order to detect, deter and prevent money laundering and other suspicious activities, it is imperative that AAAFX “know” all of its customers - both institutional and individual. To achieve sufficient knowledge about each customer, AAAFX will undertake the steps set forth below to obtain and maintain detailed customer information. This risk-based approach begins at the initial contact between the customer and AAAFX and continues during the course of the business relationship with the customer. All Employees of AAAFX are required to comply with the "Customer Identification Program” and “Know Your Customer" policies and procedures set forth below and to otherwise safeguard against money laundering activities in the performance of their everyday duties. AAAFX shall (i) conduct appropriate due diligence to know and adequately document the identity of each prospective new customer, the nature of the customer's business (employment) and the source of the customer's assets, before opening an account for the customer, (ii) keep proper records of such due diligence and the customer's transactions, (iii) report and maintain record of any suspicious activities as required by these Policies and applicable law, and (iv) participate in AAAFX sponsored educational courses and training.

(ii) Obtaining Customer Information

All prospective customers of AAAFX will be required to provide basic information prior to the opening of any account by completing, in its entirety, AAAFX's new account documentation and submitting any required supporting documents. This requirement applies to named account owners of the account in question. Under some circumstances customers may not be allowed to begin any trading activity without the receipt and review of the new account forms and any required supporting documentation. Additional due diligence may be warranted depending on the specific circumstances, including the type of customer, the customer’s home jurisdiction, and how well AAAFX already knows the customer or account applicant. Additional due diligence may include, for example, taking steps to ensure that the customer, or the source of the funds, is legitimate. On a case by case basis, requirements may be modified for a prospective new customer, if approved by Compliance or Management, with appropriate notes made on the account. Prior to opening an account with AAAFX, Non-US clients are required to submit a Tax Identification Number (TIN). US clients are required to submit copy of valid government issued identification with photo or similar safeguard. AAAFX will not accept accounts that are applying for, but have not yet received, a tax identification number. The identifying documents of prospective customers shall be reviewed and compared with other forms of identifying documentation provided by the customer. If during the course of the verification process, AAAFX identifies a discrepancy or missing information in a prospective customer’s application, AAAFX will advise the client of such deficiency and request additional information or documentation to comply with AML requirements. If the prospective customer fails to provide such additional identifying documentation requested and there is no resolution of such deficiency, AAAFX will deny the application and not open the account and, if appropriate based upon the procedures and policies below, create a Suspicious Activity Report ("SAR") (See Section vii below). All new customers of AAAFX, by completing AAAFX's new account documentation, must provide the following information and documentation (unless otherwise verified through non-documentary means):

Information Requested From Clients:

• The identity and address of the customer (Post Office boxes are not acceptable unless accompanied by appropriate documentation); • Date of birth; • Social security number or taxpayer identification number; • Citizenship status (e.g., U.S. citizen, resident alien with nationality, non-resident alien); • Investment experience; • Net worth, liquid assets and annual income; and • Occupation and/or nature of the customer's employment/business. Information Requested From Non-US Clients: • The identity and address of the customer (Post Office boxes are not acceptable unless accompanied by appropriate documentation); • Date of birth; • Passport number, alien identification card number or the number and country of issuance obtained from a submitted copy of government issued identification with photo or similar safeguard, such as a driver's license or passport (passport required for all non-resident aliens), or valid equivalent based on what is acceptable in local jurisdictions in which the customer resides; • Citizenship status (e.g., U.S. citizen, resident alien with nationality, non-resident alien); • Investment experience; • Net worth, liquid assets and annual income; and • Occupation and/or nature of the customer's employment/business. Information Requested From Companies, Trusts, Partnerships or Other Legal Entities: • The full name and address of the entity (Post Office boxes are not permitted unless accompanied by appropriate documentation); • The jurisdiction of formation and legal form of the entity; • Taxpayer identification number for US entities; • Investment experience; • The names of persons with responsibility for the management of the affairs of the entity (directors, general partners, trustees, or authorized signatories), or a copy of its annual report; • Copy of documents proving the existence of the entity (e.g., certificate of incorporation, memorandum and articles of association, trust deed, partnership agreement); and • Current list of authorized signatories or copies of powers of attorney to establish and document that the entity's representative(s) are authorized to act on the entity's behalf.

All customers will be notified in the Trading Agreement that AAAFX is requesting this information to verify the customer’s identity. All of the above information and documentation (unless otherwise verified through non documentary means) shall be obtained by the Employee, attached to the account application documentation and provided to AAAFX for processing pursuant to AAAFX's standard new account approval process. In addition, whenever a material modification is made to an existing account, (e.g., new settlors, new beneficiaries, new authorized representatives) the Employee may request copies of appropriate documentation to update and correct AAAFX's records as to the customer and must provide such documentation for processing. Additionally, in the event an individual declines to provide his/her (i) investment experience; (ii) net worth, liquid assets and annual income; or (iii) occupation and nature of the customer's employment/business, the account may nonetheless be open provided the application is approved by Compliance or Management. Verification Through Non-Documentary Records – The Department of the Treasury and the CFTC have approved the use of non-documentary methods of customer identification and verification for accounts when (i) a customer who is a natural person cannot present an unexpired, government issued identification document that bears a photograph or similar safeguard; (ii) AAAFX is presented with unfamiliar documents to verify the identity of the customer; or (iii) AAAFX does not obtain documents to verify the identity of the customer, does not meet face to face with the customer who is a natural person, or is otherwise presented with circumstances that increase the risk for AAAFX will be unable to verify the true identity of a customer through documentary methods. Although documentation may be collected by AAAFX or the referring entity, ultimately AAAFX must obtain possession of the documentation prior to opening an account.

The methods AAAFX may employ in performing identity verification through non-documentary methods include: (1)contacting a customer; (2) independently verifying the customer’s identity through the comparison of information provided by the customer with information obtained from a consumer reporting agency, public database or other reliable source; (3) checking references with other financial institutions; and (4) obtaining a financial statement from the customer, or other reasonably reliable document or source.

(iii) Identifying High Risk Accounts

Pursuant to applicable laws, rules and regulations, including but not limited to Hellenic Capital Markets Interpretive Notice to Compliance Rule 2-9 [¶ 9045], if a customer account is located in a known restricted, high risk or non-cooperative jurisdiction (“NCCT”) , or is involved in a high risk business , AAAFX shall determine what, if any, additional due diligence efforts are necessary prior to accepting the account, and if accepted, AAAFX shall determine if any additional monitoring of account activity is warranted.

(iv) Prohibited Customers

In order to determine whether a customer appears on any list of known or suspected terrorists or terrorist organizations issued by the Federal Government and designated by the Treasury Department, AAAFX will (either directly or through a third party service provider) cross-reference the names of all individual account applicants and, with respect to institutional accounts, the name of the institution and its principal owners and authorized representatives, against government issued lists and the List of Specially Designated Nationals and Blocked Persons maintained by the Hellenic treasury’s office of Foreign Assets Control or such other list of prohibited persons and entities as may be mandated by applicable law or regulation. Additionally, AAAFX shall follow all Federal directives issued in connection with the list. Under no circumstances will AAAFX open any account for, or on behalf of, any person whose name, or alias, is on such list or for any entity that has a principal owner or authorized representative whose name, or alias, is on such list. Further, AAAFX will immediately contact OFAC if a customer appears on OFAC’s Specifically Designated Nationals list. With respect to the account application of any person or entity that resides in, has connections to, or was formed in a regime subject to OFAC sanctions, the Firm will determine whether the account applicant is subject to the specific category of sanctions applicable to the regime and refuse or accept such accounts accordingly. The Firm will not open accounts for persons or entities that fall within the applicable category of sanctions or restrictions.

AAAFX will not open any account for any foreign shell bank (i.e., a bank without branches or offices in any country) unless that bank is affiliated with a domestic or foreign financial institution under the supervision of an appropriate regulatory banking authority. AAAFX will not open an account for or transact business with entities/institutions listed in AME Section 311 – Special Measures. AAAFX relies on a third party service provider to screen applicants against entities/institutions listed in AME Special Measures.

AAAFX Compliance management is also subscribed to AME email updates which will provide affirmative notice to the firm in the event additional jurisdictions or entities are added to (or removed from) the Hellenic Treasury’s Section 311 – Special measures list. In the unlikely event that an account held at AAAFX is added to the AME Section 311 list AAAFX would take one or more of the following remedial actions: (1.) freeze all activity associated with the account; (2.) notify relevant federal or local law enforcement of the existence of the account; (3.) request guidance from the Hellenic Capital Markets Division of Enforcement as to what appropriate action should be taken with respect to the account; (4.) follow any special measures that may have been imposed.

AAAFX will not open accounts for the following types of financial institutions: (1) A foreign bank operating under an offshore banking license; (2) A foreign bank operating under a license issued by a country on the Financial Action Task Force’s non-cooperative country list; or (3) A foreign bank operating under a license issued by a country designated by the Secretary of Treasury as being a primary money laundering concern .

(v) Senior Foreign Government/Public Officials

Any Employee who becomes aware of an account beneficially owned, controlled or maintained for a senior foreign government official (e.g., a head of state, high ranking military officer or bureaucrat), the close family member or associate of such an official must report such an account to Management or the AML Officer/Compliance Department. Accounts requested or maintained for or on behalf of senior foreign political figures (which includes family members and close associates), may be subject to increased scrutiny in an effort to detect and report transactions that may involve the proceeds of foreign corruption. Specific procedures detailed in the Compliance Manual apply in situations where AAAFX has determined that additional due diligence is required, if at all.

(vi) Accepted Forms of Deposits

AAAFX will accept only certain forms of deposits from its customers. Under NO circumstances will AAAFX accept cash or disburse cash to a customer. Additionally, to minimize exposure to money laundering, AAAFX discourages deposits of cash equivalents (money orders, traveler’s checks). However, AAAFX may agree to accept a deposit of a cash equivalent on a case-by-case basis with the approval of Operations Management or Compliance. Additionally, AAAFX will not accept third party checks and/or an endorsed employer’s check unless approved by Management.

(vii) Suspicious Activity Reporting

(a) Account Opening

Suspicious activity can be detected at any time during a customer's relationship with AAAFX. Certain customer conduct during the account opening process may be indicative of intent to use the account for money laundering activities. The following are examples of suspicious activities during the account opening process that may be indicative of money laundering and must be immediately reported to Management or Compliance:

• The customer, or a beneficial owner of the customer, appears on a list of sanctioned individuals or entities as maintained by OFAC; • The customer attempts to use bribery, coercion or any other improper action to open an account or conduct a transaction; • The customer exhibits unusual concern for secrecy, particularly with respect to his/her identity or background, or refuses to complete, in its entirety, AAAFX's account documentation; • The customer exhibits unusual concern regarding AAAFX's compliance with government reporting requirements, particularly with respect to his or her identity, type of business, and assets; • Upon request, the customer refuses to identify or fails to indicate a legitimate source for his/her funds and other assets or identifies a source that is fictitious, false, misleading or substantially incorrect; • The customer is reluctant to provide complete information regarding the purpose of his/her business, prior banking relationships, an entity's officers and directors or location if asked; • The customer has difficulty describing the nature of his/her business; • The customer lacks general knowledge of his/her industry; • The customer presents unusual or suspicious identification documents that cannot be readily verified; • For no apparent reason, the customer requests multiple accounts under a single name or multiple names; • The customer is from, or maintains accounts in, a country identified as a haven for money laundering; or • The customer or a person associated with the customer, has a questionable background (including prior criminal convictions) or is the subject of news reports indicating possible criminal, civil or regulatory violations.

(b) Account Monitoring

The AML Officer or his/her designees will monitor customer transactions from time to time, based on deposit and withdrawal activity, with respect to any questionable practice, high-risk characteristic or suspicious activity. Account activities subject to monitoring include, but are not limited to, the trading and flow of money into and out of an account, the types, amount and frequency of different financial instruments deposited into and withdrawn from the account and the origin and destination of wire transfers. With respect to any of the following types of accounts, the AML Officer shall determine, at the time the account is approved (or at such other time as the AML Officer learns that the account has any of the following high risk characteristics or those in Section (vii)(a)), the appropriate level and frequency of review of account activity, and shall monitor the account accordingly based on such determination: • An account from a non-FATF compliant or high-risk jurisdiction; • An account held by a senior foreign government official or the close family member or associate of such an official. The AML Officer may modify the monitoring level and frequency for any given account based upon ongoing account activity. A periodic review of accounts will be conducted to determine if the customer has been added to the Office of Foreign Asset Control ("OFAC") Blocked Persons List or other sanctions, regulatory enforcement, law enforcement and PEP lists. Further, when either the SDN list or Sanctioned Countries list is updated, AAAFX will review the existing client base to determine if any current customers are from a country on the list or any customer’s name appears on the SDN list.

AAAFX will conduct periodic activity reviews of all White Label and/or correspondent financial institution accounts held at AAAFX. These reviews will be performed by the Operations Department and should note/identify any activity that may appear unusual or suspicious. Operations will notify the Compliance Department in the event that any unusual or specific activity is identified. The Compliance Department will then undertake any further investigation and inquiry that may be required.

(c) Ongoing Account Activity

The following are activities that may occur during the business relationship with the customer and are examples of suspicious activities or characteristics that may require reporting to Management or Compliance: • A customer account has unexplained or sudden extensive wire activity, especially in accounts that had little or no previous activity; • A customer requests cash disbursements from AAAFX; • A customer's account has a large number of wire transfers to or from third parties who have no family or fiduciary relationship; • A customer's account has wire transfers at off times or unusual locations (to or from a bank secrecy haven country or country identified as a money laundering risk); • The information provided by the customer that identifies a legitimate source for funds is fictitious, false, misleading or substantially incorrect; • A customer attempts to make frequent or large deposits of currency, insists on dealing only in cash equivalents or asks for exemptions to AAAFX's policies relating to the deposit of cash and cash equivalents; • A customer makes a funds deposit, for the purpose of purchasing a long-term investment, followed shortly thereafter by a request to liquidate the position and a transfer of the proceeds out of the account; • A customer engages in excessive journal entries between unrelated accounts without any apparent business purpose; • A customer requests that a transaction be processed in such a manner so as to avoid AAAFX's normal documentation requirements; • A customer deposits bearer bonds followed by immediate request for the disbursement of funds; • A customer exhibits a total lack of concern regarding risks, commissions, or other transaction costs; • A customer's account indicates large or frequent wire transfers, immediately withdrawn by check.

According to federal law, a transaction is also "suspicious" and must be reported if it involves, in aggregate, at least $5,000 in funds or other assets and if AAAFX reasonably suspects, taking all known facts into consideration, that the funds were derived from illegal activities, or that the transaction(s) is intended to hide or disguise the illegal source of funds. In particular, suspicious transactions or series of transactions that must be reported include (i) transactions that seek to hide the ownership, nature, source, location or control of assets; (ii) transaction(s) designed to evade the currency transaction reporting requirements;(iii) transactions that attempt to use the firm to facilitate a criminal transaction; and (iv) a transaction that has no business or apparent lawful purpose, or that is not the sort in which the customer normally would be expected to engage, particularly where AAAFX has no reasonable explanation for the transaction. However, suspicious activity need not satisfy the above $5,000 threshold in order to be subject to reporting. Therefore, AAAFX Employees should report any pattern of suspicious activity, even if such pattern does not meet the $5,000 threshold noted above. The AML Officer/Compliance Department also must be notified of any instance of the receipt of an order for a reportable transaction whether or not the customer goes through with the transaction. The AML Officer/Compliance Department will file a SAR-SF with AME within 30 days after the firm becomes aware of a suspicious transaction, or within 60 days, if the identity of the suspect is unknown.”

(viii) Maintenance of Records

AAAFX requires that all Employees maintain an effective system of records and reports to keep management continuously informed of customers' activities and conditions. AAAFX may require internal and external audits to verify and supplement the Employee's records and reports. AAAFX forbids the alteration of AAAFX records for the purpose of evading AAAFX policies and procedures. A record of the evidence of each customer's identity and of all the transactions carried out by each customer shall be maintained at one of its office locations. Specifically, the retained records shall include, without limitation, (i) the documentation provided by, or completed by, the customer at the account opening, (ii) the non-documentary verification methods or additional methods used to verify identity and the results, (iii) the documentation relating to the resolution of all substantive discrepancies noted when verifying the identification information, (iv) the details of all transactions carried out by that customer, and (v) any SAR filed by AAAFX and all documentation supporting such SAR. AAAFX will maintain records as to customer identification and monitoring at a readily accessible location for the first 2 years after each account opening, and thereafter, such records shall be maintained for a period of 5 years after such account is closed. AAAFX will maintain records of any SAR filing with supporting documentation for a period of 5 years after such filing. AAAFX shall save all correspondence and supporting documentation relating to a specific SAR in an individual file. The files will be maintained separately and electronically on the firm’s data system.

(ix) Relationships between AAAFX and Foreign Financial Institution Customers From time to time, other financial institutions, such as commodity pool operators, commodity trading advisors, domestic and foreign banks, Referring Brokers, trust administrators and nominees, may introduce new customers to AAAFX, or may open accounts with AAAFX for the beneficial ownership of parties undisclosed to AAAFX. For the purposes of AAAFX's “know your customer” policies, AAAFX considers some of these financial institutions to be its customer, not such account’s beneficial owners or sub-account holders, assuming the financial institution is the principal (and not the agent) for the account and financially responsible for payment for all transactions. Since these financial institutions have direct contact and maintain the primary relationship with the ultimate beneficial owner, they are in the best position to know the underlying customer." Consequently, in certain circumstances, AAAFX may rely, consistent with this Section and these Policies, upon the anti-money laundering policies, procedures and due diligence of such third party financial institutions. The AML Officer, in consultation with AAAFX's Legal and Compliance Departments, will determine the circumstances in which it is appropriate to rely upon such third party policies and procedures and, in reaching this determination, will consider the following factors:

• The jurisdiction in which the third party is based and the existence of applicable anti-money laundering laws and regulations (in this case, AAAFX will review pronouncements of U.S. governmental agencies and multilateral organizations regarding the anti-money laundering laws and regulations in such jurisdiction); • The regulatory status of the third party and its affiliates; • The reputation and history of the third party in the investment industry; and • The anti-money laundering and due diligence policies, procedures and controls implemented by the third party. Generally, AAAFX may rely upon the anti-money laundering policies, procedures and due diligence of a U.S.- regulated financial institution or a non-U.S. regulated financial institution organized in a Financial Action Task Force (“FATF”) -compliant jurisdiction. In all such cases, AAAFX will confirm compliance with the factors noted in this section. As noted above, AAAFX will not open accounts for financial institutions operating under a license issued by a country on FATF’s NCCT list. In cases where AAAFX intends to rely upon the AML-CIP, procedures and due diligence of another third party financial institution, AAAFX will obtain a written representation from the financial institution that its anti-money laundering and due diligence policies, procedures and controls comply with applicable laws and regulations. AAAFX, in the determination of the AML Officer, also may take one or more of the following steps with respect to such financial institution: • Require the financial institution to provide AAAFX with a copy of its anti-money laundering and due diligence policies, procedures and controls and promptly to notify the AML Officer of any amendment thereto; • Require the financial institution to certify and covenant that it complies and will continue to comply with its antimony laundering and due diligence policies, procedures and controls; • Require meaningful written representations and covenants as to persons verified by the financial institution (e.g., a covenant that it will ensure that no such persons are contained on OFAC’s List of Specially Designated Nationals and Blocked Persons); • Require the financial institution to provide access, upon request, to copies of documents reviewed by the financial institution in performing its anti-money laundering due diligence; • Require the financial institution upon request to submit to a review or audit of its antimony laundering policies, procedures and controls and its compliance with the policies as they relate to AAAFX; • Obtain evidence of or representations as to its authority to open the contemplated account or make the contemplated investment; • Obtain annual ongoing verification of the financial institution’s AML-CIP.

AAAFX will perform periodic activity review of all White Label and/or correspondent financial institution accounts held at AAAFX, as set forth in Section (vii) (b) “Account Monitoring.” Notwithstanding the foregoing, if any AAAFX Employee has any reason to believe that the Anti-money laundering procedures of a financial institution customer are deficient or lacking, the Employee must contact the AML Officer or Compliance Department immediately. Upon the receipt of such information, the AML Officer may, if necessary, request from the financial institution customer, any and all documentation (e.g., antimony laundering manuals, additional representations, etc.) needed in order to determine whether the anti-money laundering policies and procedures and due diligence of the financial institution customer are sufficient, and shall undertake a review of such documentation to determine the sufficiency of such policies and procedures. Such review may be undertaken in consultation with the Legal and/or Compliance Department, as appropriate. Such review will be documented in writing, dated, and maintained in the customer's file. If the financial institution customer refuses to provide any information when requested, AAAFX will consider not opening the account. AAAFX Employees still must conduct appropriate due diligence on such financial institutions pursuant to AAAFX's "know your customer" policies. In all cases, the AML Officer shall document the steps taken in considering the account application and the reasons for approving/disapproving the account. Additionally, under certain circumstances, AAAFX may rely on a foreign financial institution for the performance of any CIP procedures set forth herein. Exhibit 8 of the AAAFX Customer Identification Program – Anti-Money Laundering Policies and Procedures outlines inquiries which can be used to assess an entity’s status as a foreign financial institution. Exhibits 6 and 7 are examples of notices AAAFX may use to confirm the existence of a foreign financial institution’s ongoing Anti-Money Laundering and Customer Identification Program (“AML-CIP”). AAAFX currently accepts correspondent banking accounts. Bank Secrecy Regulation Sec. 103.175 defines a Correspondent Account as an account established for a foreign financial institution to receive deposits from, or to make payments or other disbursements on behalf of, the foreign financial institution, or to handle other financial transactions related to such foreign financial institution. Before accepting any such correspondent banking accounts, AAAFX implements the required due diligence programs required by 31 C.F.R. 103.178(b) Section 312, Special Due Diligence for Correspondent Accounts of the Hellenic Capital Markets. AAAFX’s relationship with a correspondent banking account is relative to the status of the account. Thus, the relationship will be terminated upon the closing of the account. Additionally, AAAFX will perform periodic activity review of all correspondent financial institution accounts as set forth in Section (vii) (b) “Account Monitoring.”

Further, AAAFX shall perform risk based procedures and controls over Correspondent Accounts that will allow the firm to reasonably detect and report any known or suspected money laundering activity including: a. The nature of the foreign financial institution’s business and the markets it serves; b. The type, purpose and anticipated activity of the correspondent account; c. The nature and duration of the firm’s relationship with the foreign financial institution; d. The anti-money laundering and supervisory regime in which the foreign financial institution is chartered or licensed. e. Information known or reasonably available to the firm about the foreign financial institution’s anti-money laundering record. AAAFX does not currently accept or hold any foreign private banking accounts. Before accepting any such private banking accounts, AAAFX would adopt the required due diligence program as required by 31 C.F.R. 103.178(b)Section 312, Special Due Diligence for Correspondent Accounts and Private Banking Accounts of the Hellenic Capital Markets.

(x) Information Sharing Should any Employee receive a request or subpoena from any financial institution, government agency, self regulatory authority, or law enforcement agency to provide information regarding a past, current or prospective AAAFX customer, such request must be forwarded to the Legal and Compliance Department immediately. Additionally, AAAFX will fully cooperate with all applicable regulatory, self-regulatory, governmental and law enforcement authorities (the "Authorities") with respect to AAAFX's compliance with anti-money laundering laws and regulations. The AML Officer, Compliance Officer, or Legal Counsel shall act as the primary AAAFX contact in any matters dealing with the Authorities. Similarly, any person who has been subpoenaed or otherwise requested to disclose a SAR-SF or the information contained in a SAR-SF must decline to produce the SAR-SF and must notify AME that such a request was made, except where disclosure is requested by AME, law enforcement or a regulatory authority. Only the Compliance or Legal Departments are authorized to disclose information regarding customer accounts to third parties outside of AAAFX. AAAFX shall respond timely to all requests from appropriate authorities for information related to anti-money laundering compliance or any customer account. The AML Officer/Compliance or Legal Department shall make available to such agency information and account documentation for any account opened, maintained, administered or managed by AAAFX. Moreover, AAAFX shall effect any action requested by the Authorities, including, but not limited to, the termination of an account or the monitoring of activities in an account. Prior to complying with any request for SAR supporting documentation, AAAFX will verify the authenticity of the authority requesting the release of such information. Verification of the request will be obtained by contacting the regulatory agency whom requested the information. The Compliance or Legal Departments shall obtain a written request from any law enforcement agency which requests the firm to keep an account open with suspicious activity. AAAFX will maintain a copy of the official request for a period of five years after the request has expired. Finally, AAAFX will close a Correspondent Account within ten (10) business days of receiving written notice from the Treasury Department or the Hellenic Attorney General that the foreign bank failed either to comply with a summons or subpoena or to contest it in a Greek court.

(xi) Confidentiality All information reported by any employee regarding a suspicious activity will be held in the strictest confidence by AAAFX and not disclosed to any customer. All Suspicious Activity Reports are confidential. Furthermore, it is a violation of federal law to disclose to the customer involved, or any third party outside of AAAFX (other than law enforcement agencies or regulators), that AAAFX has filed a Suspicious Activity Report.

(xii) Audit of AAAFX’s AML Policies and Procedures An annual audit may be conducted by qualified Firm personnel not otherwise responsible for anti-money laundering compliance or by an outside auditor to evaluate and review the efficacy of AAAFX’s policies and procedures. The review shall include, without limitation, an assessment of: • Any changes in applicable laws and regulations; • The Firm’s due diligence procedures; and • A survey of changes in high-risk foreign jurisdictions.

The AAAFX AML Officer/Compliance Department shall address and correct any deficiencies found as a result of such audits and record any remedial measures taken. Audit results shall be available to the Compliance Officer or a Principal of the Referring Broker upon request.

EXHIBIT 1

High Risk Businesses The Bank Secrecy Act Comptroller's Handbook lists several "high risk" businesses that "could potentially be a source of money laundering." They are: • Casinos; • Leather-goods stores; • Car, boat and airplane dealerships; • Used car or truck dealers and machine parts manufacturers; • Travel agencies; • Jewel, gem and precious metal dealers; • Import/export companies; • Cash-intensive businesses such as restaurants, retail stores and parking garages; and • Telemarketers.

EXHIBIT 2

High Risk Jurisdictions The following list of non-cooperative countries and territories, as determined by the Financial Action Task Force, is as follows: Currently there are not any non-cooperative countries and territories. Note: The list of high-risk jurisdictions is amended periodically.

EXHIBIT 3

Member Countries of the Financial Action Task Force The following jurisdictions as determined by the Financial Action Task Force, are currently considered to have sufficient anti-money laundering regulations and enforcement: 1. Argentina 2. Australia 3. Austria 4. Belgium 5. Brazil 6. Canada 7. China 8. Denmark 9. European Commission 10. Finland 11. France 12. Germany 13. Greece 14. Gulf Co-operation Council 15. Hong Kong, China 16. Iceland 17. Ireland 18. Italy 19. Japan 20. Kingdom of the Netherlands 21. Luxembourg 22. Mexico 23. New Zealand 24. Norway 25. Portugal 26. Russian Federation 27. Singapore 28. South Africa 29. Spain 30. Sweden 31. Switzerland 32. Turkey 33. United Kingdom 34. United States Note: The list of member countries is amended periodically.

EXHIBIT 4

Office of Foreign Assets Control – Sanctioned Regimes The Office of Foreign Assets Control ("OFAC") of the Hellenic Department of the Treasury administers and enforces economic and trade sanctions against targeted foreign countries, terrorism sponsoring organizations and international narcotics traffickers based on Greek foreign policy and national security goals. OFAC has imposed sanctions upon the following regimes: • Balkans • Belarus • Burma (Myanmar) • Cote d’Ivoire (Ivory Coast) • Cuba • Democratic Republic of the Congo • Iran • Iraq • Liberia • North Korea • Sudan • Syria • Zimbabwe Note: The list of Sanctioned Regimes is amended periodically.