Exhibit 99.4

Company Anti Money Laundering (“AML”)

Official Policy (Subject to Amendment/s)

It is the policy of the company to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the Bank Secrecy Act (BSA) and its implementing regulations.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s checks, or deposited into accounts at financial institutions. At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

Although cash is rarely deposited into securities accounts, the securities industry is unique in that it can be used to launder funds obtained elsewhere, and to generate illicit funds within the industry itself through fraudulent activities. Examples of types of fraudulent activities include insider trading, market manipulation, Ponzi schemes, cyber-crime, and other investment-related fraudulent activity.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or like methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.

Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable BSA regulations and FINRA rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.

The company has designated Mr. Terry Neeley as its Anti-Money Laundering Program Compliance Person (AML Compliance Person), with full responsibility for the company’s AML program. Mr. Neeley has knowledge of the BSA and its implementing regulations and is qualified by experience, knowledge, and training. Please refer to his Bio on the last page of this policy document. The duties of the AML Compliance Person will include monitoring the company’s compliance with AML obligations, overseeing communication and training for employees. The AML Compliance Person will also ensure that the company keeps and maintains all the required AML records and will ensure that Suspicious Activity Reports (SARs) are raised to the company senior executive level for further consideration. The AML Compliance Person is vested with full responsibility and authority to enforce the company’s AML program.

The company will provide FINRA with contact information for the AML Compliance Person through the FINRA Contact System (FCS). The company will promptly notify FINRA of any change in this information through FCS and will review, and if necessary update, this information within 17 business days after the end of each calendar year. The annual review of FCS information will be conducted by Mr. Neeley and will be completed with all necessary updates being provided no later than 17 business days following the end of each calendar year. In addition, if there is any change to the information, Mr. Neeley will update the information promptly, but in any event not later than 30 days following the change.

We will respond to a Financial Crimes Enforcement Network (FinCEN) request concerning accounts and transactions by immediately searching our records to determine whether we maintain or have maintained any account for, or have engaged in any transaction with, everyone, entity or organization named in the 314(a) Request. We understand that we have 14 days (unless otherwise specified by FinCEN) from the transmission date of the request to respond to a 314(a) Request. We will designate through the FINRA Contact System (FCS) one or more persons to be the point of contact (POC) for 314(a) Requests and will promptly update the POC information following any change in such information. Unless otherwise stated in the 3l 4(a) Request or specified by FinCEN, we are required to search those documents outlined in FinCEN’s FAQ. If we find a match, Mr. Neeley will report it to FinCEN via FinCEN’ s Web-based 314(a) Secure Information Sharing System within 14 days or within the time requested by FinCEN in the request. If the search parameters differ from those mentioned above, Mr. Neeley will structure our search accordingly.

If Mr. Neeley searches our records and does not find a matching account or transaction, then Mr. Neeley will not reply to the 314(a) Request. We will maintain documentation that we have performed the required search by documenting our compliance efforts within a company on-line folder created for this purpose.

We will not disclose the fact that FinCEN has requested or obtained information from us, except to the extent necessary to comply with the information request. Mr. Neeley will review, maintain, and implement procedures to protect the security and confidentiality of requests from FinCEN like those procedures established to satisfy the requirements of Section 501 of the Gramm-Leach-Bliley Act regarding the protection of customers’ nonpublic information.

We will direct any questions we have about the 314(a) Request to the requesting federal law enforcement agency as designated in the request.

Unless otherwise stated in the 314(a) Request, we will not be required to treat the information request as continuing in nature, and we will not be required to treat the periodic 314(a) Requests as a government provided list of suspected terrorists for purposes of the customer identification and verification requirements.

The company understands that the receipt of a National Security Letter (NSL) is highly confidential. We understand that none of our officers, employees or agents may directly or indirectly disclose to any person that the FBI or other federal government authority has sought or obtained access to any of our records. To maintain the confidentiality of any NSL we receive, we will process and maintain the NSL as directed by our Chief Executive Officer. In the unlikely event, if we file a SAR after receiving an NSL, the SAR will not contain any reference to the receipt or existence of the NSL. The SAR will only contain detailed information about the facts and circumstances of the detected suspicious activity.

We understand that the receipt of a grand jury subpoena concerning a customer does not in itself require that we file a Suspicious Activity Report (SAR). When we receive a grand jury subpoena, we will conduct a risk assessment of the customer subject to the subpoena as well as review the customer’s account activity. If we uncover suspicious activity during our risk assessment and review, we will elevate that customer’s risk assessment and file a SAR in accordance with the SAR filing requirements as determined by our executive AML team, see last page. We understand that none of our officers, employees or agents may directly or indirectly disclose to the person who is the subject of the subpoena its existence, its contents, or the information we used to respond to it. To maintain the confidentiality of any grand jury subpoena we receive, we will process and maintain the subpoena by an AML subfolder. If we file a SAR after receiving a grand jury subpoena, the SAR will not contain any reference to the receipt or existence of the subpoena. The SAR will only contain detailed information about the facts and circumstances of the detected suspicious activity.

We will share information with other financial institutions regarding individuals, entities, organizations, and countries for purposes of identifying and, only where appropriate, reporting activities that we suspect may involve possible terrorist activity or money laundering. Mr. Neeley will ensure that the company files with FinCEN an initial notice before any sharing occurs and annual notices thereafter. Before we share information with another financial institution, we will take reasonable steps to verify that the other financial institution has submitted the requisite notice to FinCEN, either by obtaining confirmation from the financial institution or by consulting a list of such financial institutions that FinCEN will make available. We understand that this requirement applies even to financial institutions with which we are affiliated, and that we will obtain the requisite notices from affiliates and follow all required procedures.

We will employ strict procedures both to ensure that only relevant information is shared and to protect the security and confidentiality of this information, for example, by segregating it from the company’s other books and records.

We also will employ procedures to ensure that any information received from another financial institution shall not be used for any purpose other than:

Before entering into a transaction, and on an ongoing basis, Mr. Neeley will check to ensure that a customer does not appear on the SDN list or is not engaging in transactions that are prohibited by the economic sanctions and embargoes administered and enforced by OFAC. Because the SDN list and listings of economic sanctions and embargoes are updated frequently, we will consult them on a regular basis and subscribe to receive any available updates when they occur. With respect to the SDN list, we may also access that list through various software programs to ensure speed and accuracy. Mr. Neeley will also review existing accounts against the SDN list and listings of current sanctions and embargoes when they are updated, and he will document the review.

If we determine that a customer is on the SDN list or is engaging in transactions that are prohibited by the economic sanctions and embargoes administered and enforced by OFAC, we will reject the transaction and/or block the customer’s assets and file a rejected transaction form with OFAC within 10 days. We will also call the OFAC Hotline at (800) 540-6322 immediately.

Our review will include customer accounts, transactions involving customers (including activity that passes through the company such as wires) and the review of customer transactions that involve physical security certificates or application-based investments (e.g., mutual funds).

In addition to the information we must collect under FINRA Rules 2090 (Know Your Customer) and 2111 (Suitability) and the 4510 Series (Books and Records Requirements), and Securities Exchange Act of 1934 (Exchange Act) Rules 17a-3(a)(9) (Beneficial Ownership regarding Cash and Margin Accounts), 17a-3(a)(l 7) (Customer Accounts) and Regulation Best Interest, we have established, documented and maintained a written Customer Identification Program (CIP). We will collect certain minimum customer identification information from each customer who opens an account; utilize risk-based measures to verify the identity of each customer who opens an account; record customer identification information and the verification methods and results; provide the required adequate CIP notice to customers that we will seek identification information to verify their identities; and compare customer identification information with government-provided lists of suspected terrorists, once such lists have been issued by the government.

Prior to actively engaging in a transaction, Mr. Neeley will collect the following information for all accounts, if applicable, for any person, entity or organization that is opening a new account and whose name is on the account:

If a customer has applied for, but has not received, a taxpayer identification number, we will obtain the application to confirm that the application was filed before a transaction is consummated and to obtain the taxpayer identification number within a reasonable period after the account is opened and/or transaction initiated.

When establishing a relationship with a foreign business or enterprise, we will request alternative government-issued documentation certifying the existence of the business or enterprise before engaging in a transaction.

If a potential or existing customer or investor either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, our company will not open a new account and, after considering the risks involved, consider closing any existing account. In either case, our AML Compliance Person will be notified.

Based on the risk, and to the extent reasonable and practicable, we will ensure that we have a reasonable belief that we know the identity of our customers by using risk-based procedures to verify and document the accuracy of the information we get about our customers. Mr. Neeley will analyze the information we obtain to determine whether the information is sufficient to form a reasonable belief that we know the identity of the customer.

We will verify customer identity through documentary means, non-documentary means or both. We will use documents to verify customer identity when appropriate documents are available. Considering the increased instances of identity fraud, we will supplement the use of documentary evidence by using the non-documentary means described below whenever necessary. We may also use non-documentary means if we are still uncertain about whether we know the identity of the customer. In verifying the information, we will consider whether the identifying information that we receive, such as the customer’s name, street address, zip code, telephone number (if provided), date of birth and Social Security number, allow us to determine that we have a reasonable belief that we know the true identity of the customer.

Appropriate documents for verifying the identity of customers include the following:

We understand that we are not required to take steps to determine whether the document that the customer has provided to us for identity verification has been validly issued and that we may rely on government-issued identification as verification of a customer’s identity. If, however, we note that the document shows some obvious form of fraud, we must consider that factor in determining whether we can form a reasonable belief that we know the customer’s identity.

We will use the following non-documentary methods of verifying identity:

We will use non-documentary methods of verification when:

We will verify the information within a reasonable time before or after a transaction is underway. Depending on the nature of the account and requested transactions, we may refuse to complete a transaction before we have verified the information, or in some instances when we need more time, we may, pending verification, restrict the types of transactions or dollar amount of transactions.

We recognize that the risk that we may not know the customer’s true identity may be heightened for certain types of accounts, such as an account opened in the name of a corporation, partnership or trust that is created or conducts substantial business in a jurisdiction that has been designated by the U.S. as a primary money laundering jurisdiction, a terrorist concern, or has been designated as a non-cooperative country or territory. We will identify customers that pose a heightened risk of not being properly identified. We will also take the following additional measures that may be used to obtain information about the identity of the individuals associated with the customer when standard documentary methods prove to be insufficient.

When we cannot form a reasonable belief that we know the true identity of a customer, we will do the following: (1) not open an account; (2) impose terms under which a customer may conduct transactions while we attempt to verify the customer’s identity; (3) close an account after attempts to verify a customer’s identity fail; and (4) determine whether it is necessary to file a SAR in accordance with applicable laws and regulations.

We will document our verification, including all identifying information provided by a customer, the methods used and results of verification, and the resolution of any discrepancies identified in the verification process. We will keep records containing a description of any document that we relied on to verify a customer’s identity, noting the type of document, any identification number contained in the document, the place of issuance, and if any, the date of issuance and expiration date. With respect to non-documentary verification, we will retain documents that describe the methods and the results of any measures we took to verify the identity of a customer. We will also keep records containing a description of the resolution of each substantive discrepancy discovered when verifying the identifying information obtained. We will retain records of all identification information for five years after the account has been closed; we will retain records made about verification of the customer’s identity for five years after the record is made.

At such time as we receive notice that a federal government agency has issued a list of known or suspected terrorists and identified the list as a list for CIP purposes, we will, within a reasonable period of time after an account is opened (or earlier, if required by another federal law or regulation or federal directive issued in connection with an applicable list), determine whether a customer appears on any such list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by Treasury in consultation with the federal functional regulators. We will follow all federal directives issued in connection with such lists.

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

We will provide notice to customers that the company is requesting information from them to verify their identities, as required by federal law.

We do not open or maintain accounts for legal entity customers within the meaning of 31 CFR 1010.230. If in the future the company elects to open accounts for legal entity customers, we will first establish, document, and ensure the implementation of appropriate CDD procedures.

At the time of opening an account for a legal entity customer, Mr. Neeley will identify any individual that is a beneficial owner of the legal entity customer by identifying any individuals who directly or indirectly own 25% or more of the equity interests of the legal entity customer, and any individual with significant responsibility to control, manage, or direct a legal entity customer. The following information will be collected for each beneficial owner:

For verification, we will describe any document relied on (noting the type, any identification number, place of issuance and, if any, date of issuance and expiration). We will also describe any non-documentary methods and the results of any measures undertaken.

We will understand the nature and purpose of customer relationships for the purpose of developing a customer risk profile through the following methods.

Depending on the facts and circumstances, a customer risk profile may include such information as:

We will conduct ongoing monitoring to identify and report suspicious transactions and, on a risk basis, maintain and update customer information, including information regarding the beneficial ownership of legal entity customers, using the customer risk profile as a baseline against which customer activity is assessed for suspicious transaction reporting. Our suspicious activity monitoring procedures are detailed within Section 11 (Monitoring Accounts for Suspicious Activity).

We will identify foreign bank accounts and any such account that is a correspondent account (any account that is established for a foreign bank to receive deposits from, or to make payments or other disbursements on behalf of, the foreign bank, or to handle other financial transactions related to such foreign bank) for foreign shell banks. Upon finding or suspecting such accounts, company employees will notify the AML Compliance Person, who will terminate any verified correspondent account in the United States for a foreign shell bank. We will also terminate any correspondent account that we have determined is not maintained by a foreign shell bank but is being used to provide services to such a shell bank. We will exercise caution regarding liquidating positions in such accounts and take reasonable steps to ensure that no new positions are established in these accounts during the termination period.

We will require our foreign bank account holders to identify the owners of the foreign bank if it is not publicly traded, the name and street address of a person who resides in the United States and is authorized and has agreed to act as agent for acceptance of legal process, and an assurance that the foreign bank is not a shell bank nor is it facilitating activity of a shell bank. In lieu of this information the foreign bank may submit the Certification Regarding Correspondent Accounts for Foreign Banks provided in the BSA regulations. We will re-certify when we believe that the information is no longer accurate or at least once every three years.

We will keep records identifying the owners of foreign banks with U.S. correspondent accounts and the name and address of the U.S. agent for service oflegal process for those banks.

When we receive a written request from a federal law enforcement officer for information identifying the non-publicly traded owners of any foreign bank for which we maintain a correspondent account in the United States and/or the name and address of a person residing in the United States who is an agent to accept service of legal process for a foreign bank’s correspondent account, we will provide that information to the requesting officer not later than seven days after receipt of the request. We will close, within 10 days, any correspondent account for a foreign bank that we learn from FinCEN, or the Department of Justice has failed to comply with a summons or subpoena issued by the Secretary of the Treasury or the Attorney General of the United States or has failed to contest such a summons or subpoena. We will scrutinize any correspondent account activity during that 10-day period to ensure that any suspicious activity is appropriately reported and to ensure that no new positions are established in these correspondent accounts.

We will conduct an inquiry to determine whether a foreign financial institution has a correspondent account established, maintained, administered, or managed by the company.

If we have correspondent accounts for foreign financial institutions, we will assess the money laundering risk posed, based on a consideration of relevant risk factors. We can apply all or a subset of these risk factors depending on the nature of the foreign financial institutions and the relative money laundering risk posed by such institutions.

The relevant risk factors can include:

In addition, our due diligence program will consider additional factors that have not been enumerated above when assessing foreign financial institutions that pose a higher risk of money laundering.

We will apply our risk-based due diligence procedures and controls to each financial foreign institution correspondent account on an ongoing basis. This includes periodically reviewing the activity of each foreign financial institution correspondent sufficient to ensure whether the nature and volume of account activity is generally consistent with the information regarding the purpose and expected account activity and to ensure that the company can adequately identify suspicious transactions. Ordinarily, we will not conduct this periodic review by scrutinizing every transaction taking place within the account. One procedure we may use instead is to use any account profiles for our correspondent accounts (to the extent we maintain these) that we ordinarily use to anticipate how the account might be used and the expected volume of activity to help establish baselines for detecting unusual activity.

We will assess any correspondent accounts for foreign financial institutions to determine whether they are correspondent accounts that have been established, maintained, administered, or managed for any foreign bank that operates under:

If we determine that we have any correspondent accounts for these specified foreign banks, we will perform enhanced due diligence on these correspondent accounts. The enhanced due diligence that we will perform for each correspondent account will include, at a minimum, procedures to take reasonable steps to:

In the event there are circumstances in which we cannot perform appropriate due diligence with respect to a correspondent account, we will determine, at a minimum, whether to refuse to open the account, suspend transaction activity and close the correspondent account and/or take other appropriate action.

We do not open or maintain private banking accounts.

If FinCEN issues a final rule imposing a special measure against one or more foreign jurisdictions or financial institutions, classes of international transactions or types of accounts deeming them to be of primary money laundering concern, we understand that we must read FinCEN’s final rule and follow any prescriptions or prohibitions contained in that rule. For example, if the final rule deems a certain bank and its subsidiaries to be of primary money laundering concern, a special measure may be a prohibition from opening or maintaining a correspondent account in the United States for, or on behalf of, the Specified Banks. In that case, we will take the following steps:

We will notify our correspondent accountholders that the account may not be used to provide the Specified Banks with access to us [provide details of what the language of the notice will state].

We will transmit the notice to our correspondent accounts using the following method [specify], and we shall retain documentation of such notice.

We will take reasonable steps to identify any indirect use of our correspondent accounts by the Specified Banks. We will determine if such indirect use is occurring from transactional records that we maintain in the normal course of business. We will take a risk-based approach when deciding what, if any, additional due diligence measures we should adopt to guard against the indirect use of correspondent accounts by the Specified Banks, based on risk factors such as the type of services offered by, and geographic locations of, their correspondents.

We understand that we have an ongoing obligation to take reasonable steps to identify all correspondent account services our correspondent accountholders may directly or indirectly provide to the Specified Banks.

We will monitor account activity for unusual size, volume, pattern, or type of transactions, considering risk factors and red flags that are appropriate to our business. (Red flags are identified in Section 11.b. below.) The customer risk profile will serve as a baseline for assessing potentially suspicious activity. The AML Compliance Person or his or her will be responsible for this monitoring, will review any activity that our monitoring system detects, will determine whether any additional steps are required, will document when and how this monitoring is carried out, and will report suspicious activities to the appropriate authorities.

In situations involving violations that require immediate attention, such as terrorist financing or ongoing money laundering schemes, we will immediately call an appropriate law enforcement authority.

Potential Red Flags in Customer Due Diligence and Interactions with Customers

Potential Red Flags in Deposits of Securities

Potential Red Flags in Securities Trading

Potential Red Flags in Money Movements

Potential Red Flags in Insurance Products

Other Potential Red Flags

When an employee of the company detects any red flag, or other activity that may be suspicious, he or she will notify Mr. Neeley. Under the direction of the AML Compliance Person, the company will determine whether and how to further investigate the matter. This may include gathering additional information internally or from third-party sources, contacting the government, freezing the account and/or filing a SAR.

When senior executive management becomes aware or is otherwise informed of a suspicious transaction or a series of transactions, they will convene, review, analyze, discuss, and conclude how the company shall handle the situation.

Our company prohibits transactions involving certain currencies and has the procedures to prevent such transactions. If we discover such transactions have occurred, we will file with FinCEN CTRs for currency transactions that exceed $10,000. Also, we will treat multiple transactions involving currency as a single transaction for purposes of determining whether to file a CTR if they total more than $10,000 and are made by or on behalf of the same person during any one business day.

Our company prohibits both the receipt of currency or other monetary instruments that have been transported, mailed, or shipped to us from outside of the United States, and the physical transportation, mailing or shipment of currency or other monetary instruments by any means other than through the postal service or by common carrier.

We will file a Foreign Bank and Financial Accounts Report (FBAR) for any financial accounts of more than $10,000 that we hold, or for which we have signature or other authority over, in a foreign country.

When we issue or sell a bank check or draft, cashier’s check, money order or traveler’s check in the amounts of $3,000 to $10,000 inclusive, we will maintain records of the following information:

When we are the transmittor’ s financial institution in funds of $3,000 or more, we will retain either the original or a copy (e.g., microfilm, electronic record) of the transmittal order. We will also record on the transmittal order the following information: (1) the name and address of the transmittor; (2) if the payment is ordered from an account, the account number; (3) the amount of the transmittal order; (4) the execution date of the transmittal order; and (5) the identity of the recipient’s financial institution. In addition, we will include on the transmittal order as many of the following items of information as are received with the transmittal order: (1) the name and address of the recipient; (2) the account number of the recipient; (3) any other specific identifier of the recipient; and (4) any form relating to the transmittal of funds that is completed or signed by the person placing the transmittal order.

We will also verify the identity of the person placing the transmittal order (if we are the transmitting company), provided the transmittal order is placed in person and the transmittor is not an established customer of the company (i.e., a customer of the company who has not previously maintained an account with us or for whom we have not obtained and maintained a file with the customer’s name, address, taxpayer identification number, or, if none, alien identification number or passport number and country of issuance). If a transmittor or recipient is conducting business in person, we will obtain: (1) the person’s name and address; (2) the type of identification reviewed and the number of the identification document (e.g., driver’s license); and (3) the person’s taxpayer identification number (e.g., Social Security or employer identification number) or, if none, alien identification number or passport number and country of issuance, or a notation in the record the lack thereof. If a transmittor or recipient is not conducting business in person, we shall obtain the person’s name, address, and a copy or record of the method of payment (e.g., check or credit card transaction). In the case oftransmittors only, we shall also obtain the transmittor’s taxpayer identification number (e.g., Social Security or employer identification number) or, if none, alien identification number or passport number and country of issuance, or a notation in the record of the lack thereof. In the case ofrecipients only, we shall obtain the name and address of the person to which the transmittal was sent.

Our AML Compliance Person and his or her designee will be responsible for ensuring that AML records are maintained properly, and that SARs are filed as required.

In addition, as part of our AML program, our company will create and maintain SARs, CTRs, CMIRs, FBARs, and relevant documentation on customer identity and verification (See Section 5 above) and funds transmittals. We will maintain SARs and their accompanying documentation for at least five years if any. We will keep other documents according to existing BSA and other recordkeeping requirements, including certain SEC rules that require six-year retention periods.

We will hold SARs if any and any supporting documentation confidential. We will not inform anyone outside of FinCEN, the SEC, an SRO registered with the SEC or other appropriate law enforcement or regulatory agency about a SAR. We will refuse any subpoena requests for SARs or for information that would disclose that a SAR has been prepared or filed and immediately notify FinCEN of any such subpoena requests that we receive. We will segregate SAR filings if any and copies of supporting documentation from other company books and records to avoid disclosing SAR filings. Our AML Compliance Person will handle all subpoenas or other requests for SARs if any. We may share information with another financial institution about suspicious transactions.

We shall retain either the original or a microfilm or other copy or reproduction of each of the following:

We will work closely with our clearing firm to detect money laundering. We will exchange information, records, data, and exception reports as necessary to comply [with our contractual obligations and] with AML laws. Both our company and our clearing firm have filed (and kept updated) the necessary annual certifications for such information sharing, which can be found on FinCEN’s website. As a general matter, we will obtain and use the following exception reports offered by our clearing firm in order to monitor customer activity and we will provide our clearing firm with proper customer identification and due diligence information as required to successfully monitor customer transactions. We have discussed how each firm will apportion customer and transaction functions and how we will share information and set forth our understanding in a written document. We understand that the apportionment of functions will not relieve either of us from our independent obligation to comply with AML laws, except as specifically allowed under the BSA and its implementing regulations.

We will develop ongoing employee training under the leadership of the AML Compliance Person and senior management. Our training will occur on at least an annual basis. It will be based on our company’s size, its customer base, and its resources and be updated as necessary to reflect any new developments in the law.

Our training will include, at a minimum: (1) how to identify red flags and signs of money laundering that arise during the course of the employees’ duties; (2) what to do once the risk is identified (including how, when and to whom to escalate unusual customer activity or other red flags for analysis and, where appropriate, the filing of SARs); (3) what employees’ roles are in the company’s compliance efforts and how to perform them; (4) the company’s record retention policy; and (5) the disciplinary consequences (including civil and criminal penalties) for non-compliance with the BSA.

We will develop training in our company, or contract for it. Delivery of the training may include educational pamphlets, videos, intranet systems, in-person lectures and explanatory memos. We will maintain records to show the persons trained, the dates of training and the subject matter of their training.

We will review our operations to see if certain employees, such as those in compliance, margin, and corporate security, require specialized additional training. Our written procedures will be updated to reflect any such changes.

Our Program:

The testing of our AML program will be performed at least annually by an executive other than Mr. Neeley, personnel of our company, none of whom are related to the AML Compliance Person nor do they perform the AML functions being tested nor do they report to any such persons. Their qualifications include a working knowledge of applicable requirements under the BSA and its implementing regulations. To ensure that they remain independent, we will separate their functions from other AML activities. Independent testing will be performed more frequently if circumstances warrant.

After we have completed the independent testing, staff will report its findings to senior management and to the Board of Directors. We will promptly address each of the resulting recommendations and keep a record of how each noted deficiency was resolved.

We will subject employee accounts to the same AML procedures as customer accounts, under the supervision of the AML Compliance Person. We will also review the AML performance of supervisors, as part of their annual performance review. The AML Compliance Person’s accounts will be reviewed by another member of senior executive management.

Employees will promptly report any potential violations of the company’s AML compliance program to the AML Compliance Person, unless the violations implicate the AML Compliance Person, in which case the employee shall report to the Chief Executive Officer. Such reports will be confidential, and the employee will suffer no retaliation for making them.

The company has reviewed all areas of its business to identify potential money laundering risks that may not be covered in the procedures described above. The major additional areas of risk include large foreign and domestic transactions and transactions with foreign entities and governments. The company will coordinate AML and Countering Terrorism Financing efforts with our financial institutional partners and exchanges domestically and internationally. At least annually, a new risk assessment report will be made and presented to the Board.

Senior executive management has approved this AML compliance program in writing as reasonably designed to achieve and monitor our company’s ongoing compliance with the requirements of the BSA and the implementing regulations under it. This approval is indicated by signatures below.

Date: July 12^th 2024

Date: July 12^th 2024

AML Senior Executive Management Team Members

Chris J. Quick - CRO

Chris Quick is a CPA, Certified in Financial Forensics, and a member of the AICPA. Chris was a Founding Partner in Quick Group which specialized in Forensic Accounting. Chris spent 26 years with the FBI conducting large, complex financial investigations and 4 years with US Treasury/IRS CID. Chris has lectured at universities and law schools.

Frank Worrell - CFO

Frank Worrell is a CPA, Certified in Financial Forensics, and a member of the AICPA. Frank was a Founding Partner in Quick Group which specialized in Forensic Accounting. Frank spent 22 years with the FBI investigating large financial crimes and 6 years with US Treasury Special Inspector General overseeing the $22 billion Public-Private Investment Program managed by the world’s largest asset management companies. Frank has worked extensively with the SEC and DOJ.

Terry Neeley - Director of AML

Terry Neeley is a well-respected expert in the criminal enforcement of the Bank Secrecy Act (BSA) and Money Laundering Control Act – federal money laundering statutes (18 U.S.C. §§ 1956 and 1957). He has 25+ years of firsthand experience investigating complex international drug money laundering organizations, white collar financial crimes and terrorist financing. He was a key figure in the most significant drug money laundering investigation in U.S. history, which involved the indictment and conviction of foreign banks and twenty bankers for violations of the BSA/AML. He served at the U.S. Embassy Ottawa, Canada and Den Haag, The Netherlands, and briefed trade-based AML operations he ran to U.S. Ambassadors in Colombia and Panama, members of Congress, senior management at the Treasury and Justice Departments and Italy’s Anti-Mafia.

In 2016, Mr. Neeley concluded a six-year position with the Department of the Treasury, Special Inspector General for the Troubled Asset Relief Program and founded West Coast AML Services, LLC, a BSA/AML risk management consultancy.

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