Know Your Customer Policy (April 2007)

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Due to an Office of Foreign Assets Control (OFAC) guidelines bulletin to the corporate registration industry, as well as our identifying a need to be proactive on this issue, CorpDirect Agents implemented a Financial Crimes and Client Risk Guidelines Policy to address our Financial Crimes Risk Assessment Practices (FCRA). The implementation of our FCRA related policy is intended to ensure CorpDirect Agents will not knowingly perform service for any party identified by the General Services Administration's (GSA) Excluded Parties Listing Systems (EPLS). EPLS identifies parties the U.S. Government has deemed ineligible for U.S. government and/or business relations, specifically including Specially Designated Nationals (SDN) identified by OFAC. OFAC, which is under the U.S. Department the Treasury, publishes a list of such individuals and companies owned or controlled by, or acting for or on behalf of, certain targeted countries, including terrorists and narcotics traffickers designated under programs that are not country-specific.

Under our policy, CorpDirect Agents staff is to consider any potential customer's name (individual or business) and location, as well as principals listed in any corporate document, in making a risk assessment as to the need for further screening against the EPLS. Prior to providing service for a nonresident alien of the U.S., foreign individuals, and foreign commercial customers (companies), including company principals identified in any corporate documents arising from an international customer, we must be provided a copy of a passport, Visa or valid government identification for each such party and such proof of identification is to be searched against the EPLS.

For more information, please visit http://www.corpdirect.com/knowYourCustomer