DATACLUB LIMITED ANTI MONEY-LAUNDERING (AML) POLICY

Policy

It is the policy of DATACLUB LIMITED and its affiliates, (hereinafter "DATACLUB LIMITED") to prohibit and actively pursue the prevention of money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. DATACLUB LIMITED is committed to AML compliance in accordance with applicable laws of jurisdictions where DATACLUB LIMITED offers corporate and legal services. DATACLUB LIMITED requires its officers, employees and affiliates to adhere to these standards in preventing the use of its products and services for money laundering purposes.

For the purposes of the Policy, money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been 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. Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.

Each employee of DATACLUB LIMITED, whose duties are associated with the provision of products and services of DATACLUB LIMITED and who directly or indirectly deals with the clientele of DATACLUB LIMITED, is expected to know the requirements of the applicable laws and regulations which affect his or her job responsibilities, and it shall be the affirmative duty of such employee to carry out these responsibilities at all times in a manner that complies with the requirements of the relevant laws and regulations.

The laws and regulations include, but not limited to: "Customer Due Diligence for Banks" (2001) and "General Guide to Account Opening and Customer Identification" (2003) of Basel Committee of banking Supervision, Forty + nine Recommendations for Money Laundering of FATF, USA Patriot Act (2001), Prevention and Suppression of Money Laundering Activities Law of (1996).

To ensure that this general policy is carried out, management of DATACLUB LIMITED has established and maintains an ongoing program for the purpose of assuring compliance with the relevant laws and regulations and the prevention of money laundering. This program seeks to coordinate the specific regulatory requirements throughout the group within a consolidated framework in order to effectively manage the group’s risk of exposure to money laundering and terrorist financing across all business units, functions, and legal entities.

Each of the affiliates of DATACLUB LIMITED is required to comply with all aspects of the group’s policy as well as their own AML policies which specifically consider the local AML laws and requirements to which they are subject. Failure by the group and its affiliates to comply with the all applicable local AML laws and regulations could result in severe regulatory sanctions, possible fines and criminal penalties and damage to the group's business reputation.

Risk Assessment

An assessment of the risk of exposure to money laundering issues across all customer relationships shall be completed using the DATACLUB LIMITED standardized risk rating model. The risk rating model shall be approved by the Board of Directors on an annual basis.

Suspicious Activities

There are signs of suspicious activity that suggest money laundering. These are commonly referred to as "red flags." If a red flag is detected, additional due diligence will be performed before accepting client’s requests or providing services.

Examples of red flags are:

• The customer exhibits unusual concern regarding the AML policies, particularly with respect to his or her identity, type of business and assets, or is reluctant or refuses to reveal any information concerning business activities, or furnishes unusual or suspect identification or business documents.
• The customer wishes to engage in transactions that lack business sense or apparent investment strategy, or are inconsistent with the customer’s stated business strategy.
• The information provided by the customer that identifies a legitimate source for funds is false, misleading, or substantially incorrect.
• Upon request, the customer refuses to identify or fails to indicate any legitimate source for his or her funds and other assets.
• The customer (or a person publicly associated with the customer) has a questionable background or is the subject of news reports indicating possible criminal, civil, or regulatory violations.
• The customer exhibits a lack of concern regarding risks, commissions, or other transaction costs.
• The customer appears to be acting as an agent for an undisclosed principal, but declines or is reluctant, without legitimate commercial reasons, to provide information or is otherwise evasive regarding that person or entity.
• The customer has difficulty describing the nature of his or her business or lacks general knowledge of his or her industry.
• The customer attempts to make frequent or large deposits of currency, insists on dealing only in cash equivalents.
• For no apparent reason, the customer has multiple accounts under a single name or multiple names, with a large number of inter-account or third-party transfers.
• The customer is from, or has accounts in, a country identified as a non-cooperative country or territory by the Financial Action Task Force.
• The customer’s account has unexplained or sudden extensive wire activity, especially in accounts that had little or no previous activity.
• The customer’s account shows numerous currency or cashiers check transactions aggregating to significant sums.
• The customer’s account has a large number of wire transfers to unrelated third parties inconsistent with the customer’s legitimate business purpose.
• The customer’s account has wire transfers that have no apparent business purpose to or from a country identified as money laundering risk or a bank secrecy haven.
• The customer’s account indicates large or frequent wire transfers, immediately withdrawn by check or debit card without any apparent business purpose.
• The customer makes a funds deposit followed by an immediate request that the money be wired out or transferred to a third party, or to another firm, without any apparent business purpose.
• The 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 transfer of the proceeds out of the account.
• The customer engages in excessive journal entries between unrelated accounts without any apparent business purpose.
• The customer requests that a transaction be processed in such a manner to avoid the firm’s normal documentation requirements.
• The customer, for no apparent reason or in conjunction with other red flags, engages in transactions involving certain types of securities, such as penny stocks, bearer bonds, which although legitimate, have been used in connection with fraudulent schemes and money laundering activity. (Such transactions may warrant further due diligence to ensure the legitimacy of the customer’s activity.)

Customer Identification

DATACLUB LIMITED will document and maintain written customer identification procedures ("CIP") that will enable to form a reasonable belief that DATACLUB LIMITED knows the true identity of each customer. If the DATACLUB LIMITED is not able to verify the identity of a customer within a reasonable period of time after services or account opening request, that services shall be suspended and account will be closed. Such an account and services will be subject to increased due diligence until such time as the customer’s identity has been verified or the account has been closed and services suspended.

CIP for Natural Persons

For natural persons the following information should be obtained, where applicable:

• Legal name and any other names used (such as maiden name).
• Correct permanent address (the full address should be obtained. a Post Office box number is not sufficient).
• Telephone number, fax number, and e-mail address.
• Date and place of birth.
• Nationality.
• Occupation, public position held and/or name of employer.
• An official personal identification number or other unique identifier contained in an unexpired official document (e.g. – passport, identification card, residence permit, social security records, driving license) that bears a photograph of the customer.
• Source of wealth (where appropriate).

DATACLUB LIMITED shall verify this information by at least one of the following methods:

• Confirming the date of birth from an official document (e.g. birth certificate, passport, identity card, social security records).
• Confirming the permanent address (e.g. utility bill, tax assessment, bank statement, a letter from a public authority).
• Contacting the customer by telephone, by letter or by e-mail to confirm the information supplied after an account has been opened or other services provided (e.g. a disconnected phone, returned mail, or incorrect e-mail address should warrant further investigation).
• Confirming the validity of the official documentation provided through certification by an authorized person (e.g. embassy official, notary public).

CIP for Institutions

The underlying principles of customer identification for natural persons have equal application to customer identification for all institutions. Where in the following the identification and verification of natural persons is involved, the foregoing guidance in respect of such persons shall have equal application. The term institution includes any entity that is not a natural person.

For corporate entities (i.e. corporations and partnerships), the following information should be obtained:

• Name of institution.
• Principal place of institution’s business operations.
• Mailing address of institution.
• Contact telephone and fax numbers.
• Some form of official identification number, if available (e.g. tax identification number).
• The original or certified copy of the Certificate of Incorporation and Memorandum and Articles of Association.
• Nature and purpose of business and its legitimacy.

This information should be verified by at least one of the following methods:

• For established corporate entities – reviewing a copy of the latest report and accounts (audited, if available).
• Conducting an enquiry by a business information service, or an undertaking from a reputable and known firm of lawyers or accountants confirming the documents submitted.
  
• Undertaking a company search and/or other commercial enquiries to see that the institution has not been, or is not in the process of being, dissolved, struck off, wound up or terminated.
  
• Utilizing an independent information verification process, such as by accessing public and private databases.
  
• Obtaining prior bank references.
  
• Visiting the corporate entity, where practical.
  
• Contacting the corporate entity by telephone, mail or e-mail.

Recordkeeping

All identification documentation and services records shall be kept for the minimum period of time required by local law.