AML Policy

Table of Contents

1. William O’Neil + Company AML Policy

William O’Neil + Company, as an Institutional Brokerage Firm, has a responsibility and a commitment to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. To fulfill this goal we have implemented a specific, comprehensive, internal Anti-Money Laundering Policy. Associates of William O’Neil + Company are considered members of the William O’Neil + Company team, and individually share in the responsibility of fulfilling this commitment. To that end, all William O’Neil + Company associates are apprised of this policy so even those who don’t trade understand our obligations.

What is Money Laundering?
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: (1) 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; (2) 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; and (3) 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 attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.

The Regulations
On October 26, 2001, President George W. Bush signed into law the USA PATRIOT Act, which, among other things, strengthens the anti-money laundering provisions put into place by earlier legislation and includes new anti-money laundering provisions that are applicable to broker/dealers. These regulations apply to WON in operating Institutional Services, Institutional Trading, and The Stock Mart (“TSM”) (WON’s retail, in-house trading service operated for employee’s trading purposes).

The AML Compliance Components of William O’Neil + Company

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2. AML Compliance Officer Designation and Duties

William O’Neil + Company designates its CCO as its Anti-Money Laundering Program Compliance Officer (“AML CO”), to supervise William O’Neil + Company’s AML Program. The AML CO is qualified by experience, knowledge and training, including membership in The National Society of Compliance Professionals, and receives their monthly newsletter (the “Hotline Memo”), which identifies new industry issues, includes membership to the Securities Industry Association with access to their web information, and a weekly e-mail update. She receives an electronic subscription to the Compliance Reporter, which compiles regulatory news stories segregated by category and date. To supplement these sources, the AML CO attends regulatory conferences. William O’Neil + Company has also designated a backup AML CO.

Senior Management decided to implement a “Captain Structure” to front-line manage the AML duties and to communicate effectively within relevant departments. Each department has a Manager Captain and Department Captains.4 The Captains are trained in William O’Neil + Company AML policies and procedures and are responsible for disseminating updated information to their departments, whether it be internal or regulatory.

The supervisory duties of the AML CO include: monitoring William O’Neil + Company’s AML compliance, overseeing communication, as well as coordinating and conducting training for Captains and employees. William O’Neil + Company has reviewed NASD Rules 1021 and 1031 for any applicable registration requirements, and the AML CO is properly registered, as is the backup Compliance Officer. The AML CO and Captains will also ensure that proper AML records are kept. When warranted, the AML CO will ensure Suspicious Activity Reports (SARs) are filed. William O’Neil + Company has provided the NASD with contact information for the AML CO, including name, title, mailing address, e-mail address, telephone number and facsimile number via the NASD AML Web site. William O’Neil + Company will promptly notify NASD of any change to this information.

After each regulatory exam and internal audit of William O’Neil + Company’s AML Program, senior management will review the report to ensure compliance and update the AML Program accordingly.

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3. Giving AML Information to Federal Law Enforcement Agencies and Other Financial Institutions5

1. FinCEN Requests Under PATRIOT Act Section 314

   Under Treasury’s final regulations (published in the Federal Register on September 26, 2002), William O’Neil + Company will respond to a Financial Crimes Enforcement Network (FinCEN) requests about accounts or transactions by immediately searching our records, to determine whether we maintain or have maintained any account for, or have engaged in any transaction with, each individual, entity, or organization named in FinCEN’s request. Upon receiving a 314(a) request, the AML CO will be the point of contact regarding the request and future requests. (For changes and updates to point of contact information go to http://www.fincen.gov/poc_change_314a.pdf). Unless otherwise stated in FinCEN’s request, we are required to and will search current accounts, accounts maintained by a named suspect during the preceding 12 months, and transactions conducted by or on behalf of or with a named subject during the preceding six months. If we find a match, we will report it to FinCEN by using the Secure Information Sharing System within 14 days of receiving a 314(a) request, or by any other means specified by FinCEN. If the search parameters differ from those mentioned above (for example, if FinCEN requests longer periods of time or limits the search to a geographic location), we will follow their instructions and search accordingly. If we search our records and do not uncover a matching account or transaction, then we will not reply to a 314(a) request.

   William O’Neil + Company will not disclose the fact that FinCEN has requested or obtained information from us, except to the extent necessary to comp ly with the information request. We maintain procedures to protect the security and confidentiality of requests from FinCEN, such as those established to satisfy the requirements of Section 501 of the Gramm-Leach-Bliley Act.

   WON 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. We maintain procedures to protect the security and confidentiality of requests from FinCEN, such as those established to satisfy the requirements of Section 501 of the Gramm-Leach-Bliley Act.

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

   Unless otherwise stated in the information request, William O’Neil + Company will not be required to treat the information request as continuing in nature, and we will not be required to treat the request as a list for purposes of the customer identification and verification requirements. William O’Neil + Company will not use information provided to FinCEN for any purpose other than: (1) to report to FinCEN as required under Section 314 of the PATRIOT Act; (2) to determine whether to establish or maintain an account, or to engage in a transaction; or (3) to assist William O’Neil + Company in complying with any requirement of Section 314 of the PATRIOT Act.

2. Sharing Information With Other Financial Institutions

   William O’Neil + Company will share information about those suspected of terrorist financing and money laundering with other financial institutions for the purpose of identifying and reporting activities that may involve terrorist acts or money laundering activities, and to determine whether to establish or maintain an account or engage in a transaction. As required, William O’Neil + Company will file an initial notice with FinCEN before any sharing occurs. William O’Neil + Company will file annual notices thereafter with our primary supervisory agency using the notice form found at www.fincen.gov. Additionally, we will file an update timely upon the change of any reported information. 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 with respect to financial institutions with whom we are affiliated, and so we will obtain the requisite notices from affiliates and follow all required procedures.

   We employ strict procedures both to ensure that only relevant information is shared and to protect the security and confidentiality of this information, including segregating it from William O’Neil + Company’s other books and records and preserving the information in accordance with the prescribed record retention period. In addition to sharing information with other financial institutions about possible terrorist financing and money laundering, we will also share information about particular suspicious transactions with our clearing firm for purposes of determining whether one of us will file a SAR-SF. In cases in which we file a SAR-SF for a transaction that has been handled both by us and by the clearing firm, we may share with the clearing firm a copy of the filed SAR-SF, unless it would be inappropriate to do so under the circumstances, such as where we filed a SAR-SF concerning the clearing firm or one of its employees.

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4. Checking the Office of Foreign Assets Control (“OFAC”) List

Before opening an account, and on an ongoing basis, William O’Neil + Company will check to ensure that a customer or prospect does not appear on Treasury’s OFAC “Specifically Designated Nationals and Blocked Persons” List (SDN List). We utilize an internal automated search tool titled “The OFAC Analyzer” (using up to date data from the OFAC Web site or the NASD Web site, which also has a link). This assures that each customer or prospect is not from, or engaging in transactions with people or entities from, embargoed countries and regions listed on the OFAC Web site. Because the OFAC Web site is updated frequently, we subscribe to receive updates when they occur. Based on the procedures outlined below, the AML CO will be notified promptly in the event that Institutional Services or Institutional Trading identifies that a customer, or someone with or for whom the customer is transacting, is on the SDN List or is from or engaging in transactions with a person or entity located in an embargoed country or region. After consulting with the OFAC Hotline, the transaction will be rejected and/or we will block the customer’s assets and file a blocked assets and/or reject transaction form with OFAC. The Institutional Services department maintains electronic copies of OFAC comparisons and hard copies of potential matches cleared by the AML CO. Prior to all mass mailings, an OFAC search is conducted and a copy of the correspondence along with the OFAC search is submitted to the AML CO and the Sales Manager for documented approval, which is also maintained by the Institutional Services department.

When necessary, we will call the OFAC Hotline at 1-800-540-6322 for guidance, verification, and reporting. Our clearing firm does not provide any AML compliance related support services.

Institutional Clients
We use The OFAC Analyzer to compare the SDN List to our client lists. The occurrence of this comparison is based on the frequency the SDN List is updated. This review will compare existing accounts against the most recent SDN List. William O’Neil + Company documents the review with a sign off by the AML CO on the printed comparison results. These results are maintained by the designated Office Assistant and are retained in accordance with the prescribed record retent ion period. The Institutional Trading Operations personnel screen newly submitted sub-accounts against the SDN List. Evidence of such screening and results are maintained with the settlement instructions. These records are maintained for the prescribed period for account settlement instructions.

Institutional Prospects
Account Executives are responsible to ensure that an OFAC search is conducted prior to contacting and/or discussing our services with a prospect either in person, by phone, fax, mail, or e- mail. The Account Executives bear the responsibility of not contacting a prospect who is identified as being on the SDN List. The Account Executive and the AML CO are immediately notified when a prospect is identified as such, and the Account Executive must request and wait to receive clearance from the AML CO before this prospect can be contacted. A current copy of an OFAC comparison must be attached if the Account Executive submits a WONDA® trial form for a new prospect. All historical copies and a current copy of the OFAC review and trial paperwork are attached to the Customer Identification File (or “CIF”). These records are maintained for the prescribed period for correspondence.

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5. Customer Identification and Verification

In addition to the information we must collect under SEC Rules 17a-3(a)(9) (Beneficial Ownership regarding Cash and Margin Accounts) and 17a-3(a)(17) (Customer Accounts) NYSE Rule 405 (Diligence As To Accounts), NASD Rules 2110 (Standards of Commercial Honor and Principles of Trade), 2310 (Recommendations to Customers - Suitability), and 3110 (Books and Records), we have established, documented, and maintained a written Customer Identification Program (“CIP”). We collect certain customer identification information from each customer who opens or maintains an account. This documentation is kept in the CIF. We record customer identification information, verification methods, and the results; documents are requested of all existing clients and prospective clients are notified that certain documents are required in order to open an account. It is our policy to take reasonable measures to compare the information provided by the customers with official organizational records filed with state or other regulatory agency (corporate resolutions, partnership or LLC agreements, or records filed with the SEC). All existing accounts and sub-accounts are regularly compared to government-provided lists of suspected terrorists. Note that as previously mentioned in Section 4, all existing and prospective clients are also regularly compared to the SDN List.

Between every 24 and 36 months we send out letters to our existing clients requesting that they verify that our records are up to date and accurately reflect their current business information. If nothing has changed, no action is required from our clients, however, if changes have been made to their business or personnel, we require that our clients send us updated documents reflecting such changes. Any company updates that are supplied to us in the interim that would affect any of the CIP documentation would initiate a review of the of the company’s documents for additional changes.

1. Required Customer Information

   For institutional customers, William O’Neil + Company gathers information about the principal client through Institutional Services. This information is contained in the CIF. For the sub-accounts of the principal client, additional information is provided to Institutional Trading as required by our clearing firm and our own AML policies and procedures for settlement purposes. The AML CO reviews sub-account settlement instructions when prepared for submission to our clearing firm. Further information regarding sub-account review is documented in Sections 4 and 6.

   Prior to opening an account, we collect the following CIP documentation, as applicable, for any institutional organizations opening a new account:

   • The name of the organization
   • A business street address of the organization’s physical location (always required, even if the customer uses a PO Box for mail);
   • Documentation evidencing all individuals at each client’s organization who have the authority to transact business on its behalf; and
   • Documentation evidencing which individuals at each firm are authorized to exercise discretion on behalf of the accounts for which trades are placed with our trading desk.
   
   
2. Customers Who Refuse To Provide Information

   If a potential or existing customer either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, our firm will not open a new account and, after considering the risks involved, consider closing any existing account. In either case, our AML CO will be notified so that we can determine whether we should report the situation to FinCEN (i.e., file a Form SAR-SF). The AML CO will document on the account form of the account(s) being closed, the analysis that led to the reporting or non-reporting to FinCEN. Note: the Sales Manager may make occasional exceptions provided that the Account Executive records detailed information about the steps that were followed to obtain the documents, and their records describe their knowledge of the customer and what was reviewed for verification.

3. Verifying Information

   To the extent reasonable and practicable, William O’Neil + Company will ensure that we have a reasonable belief that we know the true identity of our customers by verifying and documenting the accuracy of the information we get about the customers of Institutional Services. In verifying customer identity, we analyze any logical inconsistencies in the information we obtain.

   William O’Neil + Company gathers information about the principal client through Institutional Services and the CIP documentation. For the sub-accounts of the principal client, additional information is provided to Institutional Trading as required by our clearing firm and our own AML policies and procedures for settlement purposes. The AML CO reviews sub-account settlement instructions when prepared for submission to our clearing firm. Further information regarding sub-account review is documented in Sections 4 and 6.

   We verify customer identity through documentary evidence, non-documentary evidence, or both. We use documents to verify customer identity when appropriate documents are available. In light of the increased instances of identity fraud, we will supplement the use of documentary evidence by using the non-documentary means described below whenever possible. We may also use such non-documentary means, after using documentary evidence, if we are still uncertain about whethe r we know the true identity of the customer. In analyzing the verification information, we will consider whether there is a logical consistency among the identifying information provided, such as the customer’s name, street address, zip code, telephone number, date of incorporation, formation of partnership, and LLC or LLP.

   Appropriate documents for verifying the identity of customers include, but are not limited to, the following:

   • For institutions, documents showing the existence of the entity, such as certified articles of incorporation, a government- issued business license, a partnership agreement, an LLC or LLP instrument, or regulatory filings; and
   • For an individual representative of an institution, regulatory registration information is on file with the various governing bodies. As a supplement, William O’Neil + Company will request documentation from the institution evidencing that they are aware that the individual receives our equity data research services for their brokerage business with that institution.

   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 a government- issued identification as verification of a customer’s identity. If, however, we note that any document shows some obvious form of fraud, we consider that factor in determining whether we can form a reasonable belief that we know the customer’s true identity.

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

   • Visiting a customer at their place of business and maintaining records of those visits;
   • Checking references with other financial institutions; or
   • Obtaining an annual report or a financial statement.

   We use non-documentary methods of verification in the following situations: (1) when the customer is unable to present an unexpired government-issued document; (2) when William O’Neil + Company is unfamiliar with the documents the customer presents for identification verification; (3) when the customer and firm do not have face-to-face contact; and (4) when there are other circumstances that make it difficult for William O’Neil + Company to verify the true identity by documentary means.

   William O’Neil + Company will verify the information within a reasonable time before the account is opened. If account documents have not been reviewed and verified, services will not be activated. In addition, review of preliminary documentation is required before a trial is approved for prospective clients. Manager Captain, Henry D’Atri, Sales Manager of the Institutional Services department, is responsible for the review and approval of trial and CIP documents prior to the opening of an account. If we find suspicious information that indicates possible money laundering or terrorist financing activity, we will, after internal consultation with William O’Neil + Company’s AML CO, file a SAR-SF in accordance with applicable law and regulation.

   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 United States as a primary money laundering concern or has been designated as non-cooperative by an international body. We identify customers that pose a heightened risk of not being properly identified. Due to the specific profile of all customers of William O’Neil + Company, senior management is confident that the identity of all customers will be verified. However, additional measures that may be used are outlined in section d. that follows.

4. Lack of Verification

   Institutional Prospects
   When William O’Neil + Company cannot form a reasonable belief that we know the true identity of a prospect, we will do the following: (1) not allow a WONDA trial; or (2) impose specific terms under which a prospect may receive a trial while we attempt to verify the customer’s identity.

   Institutional Clients
   When William O’Neil + Company 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) in circumstances where the client is a well known entity, William O’Neil + Company will accept publicly available documentation with specific notes of the Account Executive’s relationship and knowledge of the customer, which we refer to as a Past History Declaration Memo. In the second instance, two senior officers must approve the account documentation.

5. Recordkeeping

   Institutional Services maintains the CIP documentation for each customer in a central file in alphabetical order. Institutional Services documents the identity verification of each customer through the comparison of documents provided by the customer to information publicly available. If Institutional Services uses non-documentary verification, they will retain documents that describe the methods and the results of any measures taken to ve rify the identity of a customer. Institutional Trading maintains settlement instructions for all subaccounts in a centralized file, by account number, in the trading department. The AML CO indicates her verification and review of the sub-account information with her signature on the form. Institutional Services and Institutional Trading will maintain records of all identification information for the life of the account and for at least five years after the account has been cancelled.

6. Comparison with Government Provided Lists of Terrorists and Other Criminals

   As outlined in Section 4, William O’Neil + Company will do an OFAC comparison with all existing accounts. The occurrence of this comparison is based on the frequency of the SDN List being updated, through an in house automated system. From time to time, William O’Neil + Company may also receive notice that a Federal government agency has issued a list of known or suspected terrorists or posted a notice regarding recent suspicious transactions. 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), we will 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 follow all Federal directives issued in connection with such lists.

   We continue to comply with Treasury’s Office of Foreign Asset Control rules prohibiting transactions with certain foreign countries or their nationals.

7. Notice to Customers

   We have provided written notice to all existing customers of IS that documentation is required for us to comply with Federal Regulations. We provide notice to customers via WON’s Web site that WON requests information from them to verify their identities, as required by Federal law. The following language is posted:

   Important Information About Our Account Requirements
   To help the government fight the funding of terrorism and money laundering activities, Federal law requires financial institutions to obtain, verify, and record customer account information. At William O’Neil + Company, we collect public and nonpublic information about our institutional clients as specifically mandated for customer identification and verification by the US PATRIOT ACT, SEC 17a-3 (Books & Records Requirements), NYSE Rule 405 (“Know Your Customer”) and NASD Conduct Rule 3110.

   This Notice provides you with some answers about William O’Neil + Company’s Customer Identification Program.

   What types of information will I need to provide?
   For an institutional account to be opened, William O’Neil + Company is required to record and verify:

   • The name(s) of the person(s) authorized to conduct business on behalf of your organization; and
   • Whether or not your organization intends to have associates trade with our equity desk. If your organization does intend to have associates trade with our equity desk, we will need a trading authorization listing those associates and signed by a party authorized to conduct business on behalf of your organization;

   For your convenience, we have developed fill-in-the blank forms that, if filled in completely and accurately, will satisfy the above requirements. When filling out the form, if any of the specified terms do not apply, please make the necessary changes so that all the information will reflect your organization appropriately, or contact your Account Executive to help have a customized version created for you that satisfies our requirements and better addresses your organization’s structure.

   • A corporation, partnership, trust or other legal entity must also provide information about its principal place of business and local office(s) with which we have a business relationship, as noted within one of the following documents: certified articles of incorporation, government-issued business license, LLC agreement(s), and partnership or trust agreement(s) as applicable to the organization of the firm.

   What happens if I don’t provide the information requested or my identity can’t be verified?

   If the above information is not provided or your organization’s identity cannot be verified, William O’Neil + Company will be unable to open an account or carry out transactions for your organization, and consequently any already existing accounts may have to be closed. If you have not yet done so, please contact your Account Executive to provide any of the necessary information noted above.

8. Reliance on Another Financial Institution for Identity Verification

   With regard to the sub-accounts of our principal clients for which we process trades, William O’Neil + Company relies on the expectation that the principal account who has the relationship with their customer (the sub-account ) for whom they trade on behalf of with us, has their own customer identification program. This obligates them to verify the identity of the customers they introduce to William O’Neil + Company. This reliance is based on the fact that our clients have a fiduciary responsibility to their customer and occurs when:

   • This reliance is reasonable under the circumstances; or
   • That the other financial institution is subject to a rule implementing the antimoney laundering compliance program requirements of 31 U.S.C. 5318(h), and is regulated by a Federal functional regulator.

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6. Foreign Correspondent Accounts and Foreign Shell Banks

1. Detecting and Closing Correspondent Accounts of Unregulated Foreign Shell Banks Foreign Correspondent Accounts

   A “Correspondent account” is defined as an account that has been established at a U.S. financial institution by a foreign financial institution to receive deposits from or to make payments or other distributions on behalf of, the foreign financial institution, or to handle other financial transactions related to such foreign financial institution

   William O’Neil + Company will conduct the following general due diligence in respect of any foreign financial institution that maintains a correspondent account at the U.S. institution:

   1. Determine whether the account is subject to enha nced due diligence under Section 312 based on the risks associated with the particular account.
   2. Assess the money laundering risk posed after considering: (a) the nature of the foreign financial institution’s business and the markets it serves; (b) the type, purpose and anticipated activity of such correspondent account; (c) the nature and duration of the relationship with the foreign financial institution; (d) the AML regime of the home country of the foreign financial institution; and (e) information known about the AML record of the foreign financial institution.
   3. Apply risk-based policies, procedures, and controls to each correspondent foreign account designed to report and detect money laundering activity, including a periodic review of the foreign correspondent account activity.

   William O’Neil + Company will detect foreign correspondent accounts by strictly adhering to our CIP (described in section 5). Specifically, we review each sub-account as it opens to determine the settlement instructions. The settlement instructions will identify the institutions used by those sub-accounts as noted on the account instructions page maintained by Institutional Trading. Institutional Trading Operations personnel reviews each instruction page to determine if the institution William O’Neil + Company’s clearing firm is settling with is in the United States. The AML CO reviews all subaccount forms. This satisfies the requirement for “reasonable steps” to be taken to ensure that William O’Neil + Company only introduces customers to our clearing firm who utilize U.S. institutions for settlement.

   Special Due Diligence for Foreign Banks
   By adhering to our CIP, William O’Neil + Company will determine whether any foreign correspondent account is maintained for a foreign bank that operates under offshore banking licenses or under a banking license issued by certain jurisdictions specified in 31 C.F.R. §103.176 (c) [See http://www1.oecd.org/fatf/NCCT_en.htm]. For such correspondent accounts, William O’Neil + Company would apply the enhanced due diligence requirements of 31 C.F.R. §103.176 (b), which includes enhanced scrutiny, a determination whether the foreign bank maintains its own correspondent accounts for other foreign banks, and identification of certain owners of the foreign bank. In appropriate circumstances, the enhanced scrutiny will include closer monitoring of account activity, obtaining information about sources and beneficial ownership of funds, identifying persons with trading authority, and obtaining a completed US Treasury Department Foreign Bank Certification.

   If we are considering opening a new account that would be subject to this enhanced due diligence, the Account Executive would consult with the designated AML Captain for Institutional Services. If we cannot perform due diligence adequately, we would not open the account.

   Foreign Shell Banks
   It is William O’Neil + Company’s policy not to establish, maintain, administer, or manage correspondent accounts for unregulated foreign shell banks. The institution settling the transaction on behalf of the sub-account carries the responsibility of confirming that they are not indirectly providing correspondent banking services to foreign shell banks. Please also refer to Section 5.h.

   Upon finding or suspecting unregulated foreign shell bank accounts, the AML Captains will notify the AML CO, who will terminate any verified correspondent account in the United States for an unregulated foreign shell bank. We will also terminate any correspondent account that we have determined is not maintained by an unregulated foreign shell bank but is being used to provide services to such a shell bank. All institutional client trading accounts with William O’Neil + Company are set up as DVP/RVP, whereby settlement is processed by William O’Neil + Company’s clearing firm and the US clearing firm of the sub-account. However, if William O’Neil + Company were to identify the need to liquidate positions, we would exercise caution in doing so in such accounts and take reasonable steps to ensure that no new positions are established in these accounts during the termination period. We will terminate any correspondent account for which we have not obtained the information described in Appendix A of the proposed regulations regarding shell banks within the time periods specified in those regulations.

2. Certifications

   William O’Neil + Company requires our foreign bank clients to complete a foreign bank certification issued by Treasury, which requires them to certify that they are not shell banks and to provide ownership and agent information. We will re-certify when we believe that the information is no longer accurate and at least every three years. If any prospective client failed to provide us with the required certification, we would not engage them as a client.

3. Recordkeeping for Foreign Financial Institutions

   William O’Neil + Company has a limited number of foreign financial institutions as clients. If the foreign financial institution is a foreign bank, we maintain a foreign bank certification. William O’Neil + Company maintains detailed customer information for all accounts. We will verify every 24-36 months that this information has not changed.

4. Summons or Subpoena of Foreign Bank Records; Termination of Correspondent Relationships.

   If William O’Neil + Company were to receive a written request from a Federal law enforcement officer for information concerning correspondent accounts, we will promptly provide that information to the requesting officer not later than 7 days after receipt of the request. We will close, within 10 days, any account for a bank that we learn from Treasury or the Department of Justice, has failed to comply with a summons or has contested a summons. We will scrutinize any 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 accounts.

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7. Private Banking Accounts/Foreign Officials

William O’Neil + Company’s policy prohibits the opening of “private banking” accounts. We have reviewed our accounts and determined that we have no private banking accounts and therefore we do not need to conduct due diligence on such accounts. The AML Captains will notify the AML CO upon identification or suspicion of a private banking relationship. If a true private banking account were to be identified, we would perform the required due diligence by conducting at a minimum, the following: (1) ascertaining the identity of all beneficial owners over the account (Beneficial Owner is defined as an individua l who has a level of control over, or entitlement to, the funds or assets in the account that, as a practical matter, enables the individual, directly or indirectly, to control, direct or manage the account); (2) ascertaining the source of funds deposited into the account; (3) ascertaining whether any such holder may be a senior foreign political figure; and (4) detecting and reporting, in accordance with applicable law and regulation, any known or suspected money laundering and/or use of the proceeds of foreign corruption. Additionally, our AML CO, will as appropriate, instruct the Account Executive not to open the private banking account, or AML CO will suspend the transaction activity, file a SAR, or close the account pursuant to our policy against offering private banking accounts.

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8. Monitoring Accounts For Suspicious Activity

Presently, we manually monitor a sufficient amount of account activity to permit identification of patterns of unusual size, volume, pattern or type of transactions, geographic factors such as whether jurisdictions designated as “non-cooperative” are involved, or any of the “red flags” identified in Section 8. b. below. We look at transactions, including trading and wire transfers, in the context of other account activity to determine if a transaction lacks financial sense or is suspicious because it is an unusual transaction or strategy for that customer. The AML CO and AML Captains are responsible for monitoring, documenting, and reporting suspicious activities. The AML Captains report findings to the AML CO, and the AML CO conveys any final reporting to appropriate authorities. The AML CO will determine whether to file a Form SAR-SF based on irregularities, inconsistencies, and suspicious patterns in transaction size, location, type, number, and nature of the activity. Our AML CO will conduct an appropriate investigation before a SAR is filed. Our monitoring of specific transactions is multi- layered: first the AML Captains review daily, weekly, and quarterly transactions followed with oversight by the AML CO, all of which is documented with individual initials on the documents reviewed. The daily reviews will identify specific transactional irregularities, where the monthly reviews will provide pattern identification, and the quarterly reviews give a broader perspective of overall account activity.

1. Emergency Notification to the Government by Telephone

   When conducting due diligence or opening an account, the AML CO will promptly call Federal law enforcement when necessary. The following circumstances would constitute immediate notification: a legal or beneficial account holder or person with whom the account holder is engaged in a transaction is listed on or located in a country or region listed on the SDN List, an account is held by an entity that is owned or controlled by a person or entity listed on the SDN List, a customer tries to use bribery, coercion, or similar means to open an account or carry out a suspicious activity, we have reason to believe the customer is trying to move illicit cash out of the government’s reach, or we have reason to believe the customer is about to use the funds to further an act of terrorism. In response to such findings, we will first call the OFAC Hotline at 1-800-540-6322. The other contact numbers we will use are: Financial Institutions Hotline (1-866-556-3974), local U.S. Attorney’s Office (1-916-445-9555), local FBI Office (1-310-477-6565), and local SEC Office (1-323-965-3998).

2. Red Flags

   Red flags that signal possible money laundering or terrorist financing include, but are not limited to:

   • The customer exhibits unusual concern about William O’Neil + Company’s compliance with government reporting requirements and William O’Neil + Company’s AML policies (particularly concerning 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 suspicious 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 or investment strategy;
   • The information provided by the customer that identifies a legitimate source for funds is false, misleading, or substantially incorrect;
   • 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 is from, or has accounts in, a country identified as a non-cooperative country or territory by the Financial Action Task Force (FATF);
   • The customer or vendor makes multiple unexplained or sudden extensive wire requests or transfers that have no apparent business purpose, especially in accounts that had little or no previous activity, or the transfers are to or from a country identified as a money laundering risk;
   • The customer requests that a transaction be processed contrary to William O’Neil + Company’s normal documentation requirements;
   • Follow up documentation that does not match information given over the phone or via the Internet at the account opening;
   • Transactions or requests seemingly designed to, or attempting to avoid reporting and recordkeeping requirements;
   • Parties or businesses that do not meet our standard customer profiles – unregistered/unlicensed businesses or unfamiliar account documentation;
   • Unusual mixed forms of payments – money orders, third party checks, or personal checks.
3. Responding to Red Flags and Suspicious Activity

   When an AML Captain detects any red flag, or is notified of such, he or she will investigate further under the direction of the AML CO. This may include gathering additional information internally or from third-party sources. The AML CO is responsible for contacting the government, freezing an account, or filing a Form SAR-SF when appropriate.

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9. Suspicious Transactions and BSA Reporting

1. Filing a Form SAR-SF

   William O’Neil + Company will file a Form SAR-SF for any account activity (including deposits and transfers) conducted or attempted through our firm involving (or in the aggregate) $5,000 or more of funds or assets where we know, suspect, or have reason to suspect: (1) the transaction involves funds derived from illegal activity or is intended or conducted in order to hide or disguise funds or assets derived from illegal activity as part of a plan to violate or evade Federal law or regulation, or to avoid any transaction reporting requirement under Federal law or regulation; (2) the transaction is designed, whether through structuring or otherwise, to evade any requirements of the BSA regulations; (3) the transaction has no business or apparent lawful purpose or is not the sort in which the customer would normally be expected to engage, and we know, after examining the background along with the possible purpose of the transaction and other facts, of no reasonable explanation for the transaction; or (4) the transaction involves the use of William O’Neil + Company to facilitate criminal activity.

   We do not base our decision on whether to file a SAR-SF solely on whether the transaction falls above a set threshold. We will file a SAR-SF and notify law enforcement of all transactions that raise an identifiable suspicion of criminal, terrorist, or corrupt activities.[See: NtM 02-21, page 9.] In high- risk situations, we will notify the government immediately (See Section 8 for contact numbers) and will file a SAR-SF with FinCEN. Securities law violations that are reported to the SEC or a Self-Regulatory Organization (SRO) may also be reported promptly to the local U.S. Attorney, as appropriate.

   We will not file SAR-SFs to report violations of Federal securities laws or SRO rules by our employees or registered representatives that do not involve money laundering or terrorism, but we will report them to the SEC or SRO. [See: NtM 02-21, page 10, n.35.]

   All SAR-SFs will be periodically reported to the Board of Directors and senior management, with a clear reminder of the need to maintain the confidentiality of the SAR-SF.

   William O’Neil + Company’s AML Captains and the AML CO monitor a sufficient amount of account activity to permit identification of patterns of unusual size, volume, pattern or type of transactions, geographic factors such as whether jurisdictions designated as “noncooperative” are involved, or any of the “red flags” identified in Section 8. b. above. William O’Neil + Company will report suspicious transactions by completing a SAR-SF and we collect and maintain supporting documentation as required by the BSA regulations. William O’Neil + Company will file a SAR-SF no later than 30 calendar days after the date of the initial detection of the facts that constitute a basis for filing a SAR-SF. If no suspect is identified on the date of initial detection, we may delay filing the SAR-SF for an additional 30 calendar days pending identification of a suspect, but in no case, will the reporting be delayed more than 60 calendar days after the date of initial detection.

   William O’Neil + Company will retain copies of any SAR-SF filed and the original or business record equivalent of any supporting documentation for at least seven years from the date of filing the SAR-SF. We identify and maintain supporting documentation and make such information available to FinCEN, any other appropriate law enforceme nt agencies, or Federal or state securities regulators, upon request. (See also section 10 a. below)

   We will not notify any person involved in the transaction that the transaction has been reported, except as permitted by the BSA regulations. Except where disclosure is requested by FinCEN, the SEC, another appropriate law enforcement or regulatory agency, or an SRO registered with the SEC, we understand that anyone who is subpoenaed or required to disclose a SAR-SF or the information contained in the SAR-SF will decline to produce the SAR-SF or to provide any information that would disclose that a SAR-SF was prepared or filed. For such subpoenas or requests, prior to acting, William O’Neil + Company will engage outside counsel. We will notify FinCEN of any such request and our response. (See also section 10 a. below)

2. Currency Transaction Reports (CTR)

   William O’Neil + Company prohibits the receipt of currency. This policy is long standing and is documented in the AML Program, which all associates are encouraged to read upon hire and every year thereafter. If currency is received, the AML CO is notified immediately who then notifies FinCEN of the return. A photocopy record of the “currency” is maintained along with receipt of return mailing. Even after the currency is returned, if instructed by FinCEN, William O’Neil + Company will file a CTR for that reported receipt of “currency” that exceeds $10,000. William O’Neil + Company is aware that multiple transactions should be treated as a single transaction if they total more than $10,000 during any one-business day. William O’Neil + Company is aware that the CTR form is available at http://www.fincen.gov/reg_bsaforms.html#4789. The AML CO will maintain copies of the “currency” and any filed forms in her CTR files for at least seven years.

3. Currency & Monetary Instrument Transportation Reports (CMIR)

   William O’Neil + Company prohibits the receipt of monetary instruments as well as currency as described above. Because it is William O’Neil + Company’s policy to return any currency or monetary instruments received, the AML CO will file with the Commissioner of Customs a CMIR in the event William O’Neil + Company transports, mails, ships, receives, or causes or attempts to transport, mail, ship or receive monetary instruments of more than $10,000 at one time (on one calendar day or, if for the purpose of evading the reporting requirements, on one or more days) in or out of the United States. William O’Neil + Company is aware that a CMIR must be filed for all such shipments or receipts of monetary instruments, except for currency or monetary instruments shipped or mailed through the postal service or by common carrier. We will, however, file a CMIR for such receipts of currency and monetary instruments and for shipments and deliveries made by William O’Neil + Company by means other than the postal service or common carrier, even when such shipment or transport is made by William O’Neil + Company to an office of William O’Neil + Company located outside the United States (note: at this time, William O’Neil + Company does not have any offices outside the U.S. or any plans to have such). We will use the CMIR Form at http://www.fincen.gov/reg_bsaforms.html#4790. The AML CO will maintain copies of all such filed forms in her CMIR files for at least seven years.

4. Foreign Bank and Financial Accounts Reports (FBAR)

   William O’Neil + Company does not maintain or plan to maintain any hold accounts with foreign financial institutions, nor does William O’Neil + Company have a financial interest in or authority over any accounts in foreign countries. William O’Neil + Company’s AML CO would file an FBAR with FinCEN if a situation existed where we maintained a financial account of more than $10,000 or if William O’Neil + Company had signature or other authority over any accounts in a foreign country. The AML CO will use the FBAR Form at http://www.fincen.gov/f9022-1.pdf.

5. Transfers of $3,000 or More Under the Joint and Travel Rule

   While it is not currently William O’Neil + Company’s policy to transfer funds, if an exception were made and a transfer of $3,000 or more were to be processed, we would record, in writing, on the transmittal order, at least the following information: the name and address of the transmitter and recipient, the amount of the transmittal order, the identity of the recipient’s financial institution, and the account number of the recipient. In an interview with the AML CO, William O’Neil + Company will verify the identity of transmitters and the purpose of the transfer to determine if an exception will be made. If the purpose is determined to be permissible, William O’Neil + Company will confirm the existence and veracity of the recipient’s information. In the AML CO’s absence such exception could be granted by the CFO or President who would follow the same interviewing and verification procedures. Documentation of any exceptions will be maintained in the accounting files for the prescribed period for transfers.

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10. AML Record Keeping

1. SAR-SF Maintenance and Confidentiality

   William O’Neil + Company regards SAR-SFs and any supporting documentation as highly confidential. We will not inform anyone outside of a law enforcement or regulatory agency or securities regulator about a SAR-SF. We will refuse any subpoena requests for SAR-SFs or SAR-SF information and immediately inform FinCEN of any such subpoena we receive. In addition, as noted above, William O’Neil + Company will engage outside counsel prior to acting. The AML CO will segregate SAR-SF filings and copies of supporting documentation from other firm books and records to avoid disclosing SAR-SF filings. William O’Neil + Company’s AML CO will handle all subpoenas or other requests for SAR-SFs in order to maintain confidentiality. The records are maintained in the AML CO’s office for which access is limited to the President, AML CO, and back up CO. Physical records are maintained in the AML CO’s office for no less than one year, after which they are moved to William O’Neil + Company’s secure archive facility. Access to the archived records is also restricted.

   As noted in our clearing agreement, and allowed by Section 314 of the USA PATRIOT Act, William O’Neil + Company may work with the clearing firm on suspicious transactions in order to determine when a SAR-SF should be filed. As mentioned earlier, we may share with the clearing firm a copy of the filed SAR-SF unless it would be inappropriate to do so under the circumstances, such as where we file a SAR-SF concerning the clearing firm or its employees.

2. Responsibility for AML Records and SAR Filing

   William O’Neil + Company’s AML CO and her designees are responsible to ensure that AML records are maintained properly and that SARs are filed as required. All SARs will be periodically reported to senior management and documented annually in the annual report to the CEO with a clear reminder of the need to maintain the confidentiality of the SARs.

3. Records Required

   As part of our AML program, William O’Neil + Company will create and maintain: (1) relevant documentation on customer identity and verification (See Sections 5 and 9 above); (2) records related to customers listed on the SDN List; (3) funds transfers and transmittals ; and (4) SAR-SFs, CTRs, CMIRs, FBARs (as necessary). All AML and BSA records and accompanying documents will be maintained for at least seven years. (Note: SARs retention requirement is five years and BSA records are required by the SEC to be retained for six years.)

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11. Clearing/Introducing Firm Relationships

In August of 2006, Merrill Lynch (“ML”), our clearing firm, and William O’Neil + Company entered into a new an Amended and Restated Clearing Agreement specifically addressing the adoption of the AML requirements proscribed by the USA PATRIOT Act. In this agreement ML outlined the role ML expected William O’Neil + Company to take as the introducing firm. As stipulated in NASD NtM 02-21, as the introducing firm, William O’Neil + Company has the best opportunity to know and understand our clients, and we therefore take full responsibility for acting as the first line of defense in detecting and deterring suspicious activity. However, the amendment was identified by our outside independent AML examiner, PricewaterhouseCoopers LLP (“PwC”), to be somewhat lacking in outlining the clearing firm’s responsibilities. Based upon this criticism we sought to have ML clarify their clearing responsibilities. ML made it clear to us that they expect William O’Neil + Company to bear 100% of the detection, review and reporting responsibilities of all AML activities. ML indicated that automated detection systems, “ad hoc reporting” are available on BCOL (Broadcort online), however William O’Neil + Company did not receive notification or training on this valuable function.

NASD Rule 3230 stipulates that introducing and clearing firms share responsibility under the Money Laundering Abatement Act. Until ML shares in the AML responsibilities, or until we engage a new clearing firm, William O’Neil + Company will perform 100% of the necessary obligations to comply with AML laws. William O’Neil + Company works diligently to detect money laundering.

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12. Training Programs

William O’Neil + Company delivers ongoing employee training under the leadership of the AML CO, senior management, and AML Captains. Our training occurs on at least an annual basis. It is based on our firm’s size, its customer base, and its resources.

At a minimum, William O’Neil + Company’s training covers the following: how to identify red flags and signs of money laundering that arise during the course of the employees’ duties, what to do once the risk is identified, what employees’ roles are in William O’Neil + Company’s compliance efforts and how to perform them, William O’Neil + Company’s Record Retention Policy, and the disciplinary consequences (including civil and criminal penalties) for non-compliance with the PATRIOT Act.

Delivery of the training may include intranet systems, in-person lectures, and explanatory memos. Currently our training program focuses on affected departments: Institutional Services, Institutional Trading, and Accounting covering deposits and wires, OFAC/FATF and FinCEN review, CIP procedures, and suspicious “red flag” activities. All affected new employees are appropriately trained in a timely manner. William O’Neil + Company maintains records reflecting the persons trained, the dates of training, and the subject matter of their training.

Senior management reviews the firms operations regularly. If specialized additional training is deemed necessary, the appropriate personnel would be so trained. Our written procedures will be updated to reflect any changes.

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13. Program to Test AML Program

1. Staffing

   PricewaterhouseCoopers LLP, an independent third party, performs annual testing to assess our AML program. Their qualifications include: extensive experience conducting money laundering risk and control assessments, focused investigations, solution implementation efforts, and several of PwC’s professionals served in the anti-money laundering regimes of a number of countries, including the United States.

2. Evaluation and Reporting

   Each year PwC conducts an extensive in- house review in accordance with Standards for Consulting Services established by the American Institute of Certified Public Accountants. After PwC completes the testing William O’Neil + Company receive s a detailed report. The AML CO works with senior management to address each of the findings and recommendations by implementing necessary procedures and updating any policies as needed.

   As required in Section 352 of the USA Patriot Act and by NYSE Rule 445, this review process will be conducted annually. Each review will assess William O’Neil + Company’s current AML compliance program and test for compliance with the policies and procedures of that program.

   Additionally, the AML CO performs periodic reviews of CIFs, including correspondent accounts, both independently, and as identified by regulatory exams and in-house reviews.

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14. Monitoring Employee Conduct and Accounts

William O’Neil + Company subjects employee accounts to the same AML procedures as institutional client accounts. The AML CO reviews all account statements on a monthly basis, with initials evidencing review. William O’Neil + Company also reviews the AML performance of supervisors, as part of their annual performance review. The President of William O’Neil + Company would review the AML CO’s accounts if she had any.

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15. Confidential Reporting of AML Non-Compliance

Employees are instructed, as noted in the Compliance Manual, to report any violations of William O’Neil + Company’s AML Program to the AML CO. If the violations implicate the AML CO, the employee shall report to the President. Such reports are confidential, and as outlined in the Compliance Manual, the employee will suffer no retaliation for making them.

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16. Additional Areas of Risk

William O’Neil + Company has reviewed all areas of its business to verify that all potential money laundering risks are covered in the procedures described above. No additional areas of risk exist and therefore, no other procedures are necessary at this time.

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17. Senior Manager Approval

We have reviewed and approved this AML program as reasonably designed to achieve and monitor William O’Neil + Company’s ongoing compliance with the requirements of the USA PATRIOT Act and the BSA and the implementing regulations under it.

Susan McKnight, President & COO, reviewed and approved December 2006
Don Drake, Chief Financial Officer, reviewed and approved December 2006
Elizabeth Wilson, CCO and AML CO, reviewed and approved December 2006

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1. Resources: NtM 02-21, page 5; SIA Preliminary Guidance for Deterring Money Laundering Activity (“SIA Guidance”), at pages 2-3 (Feb. 2002).
2. Rule(s): NASD Rule 3011. Resources: NtM 02-78. Firms submit their AML Compliance Officer information through the NASD Contact System (NCS) by entitlement.
3. William O’Neil + Company’s Chief Compliance Officer (CCO) is Elizabeth Wilson and the backup Compliance Officer and AML CO is Robert Thompson.
4. Institutional Trading: Captains are Marlyss Cranford, Sandra Mercer and LaRonda Calloway. Institutional Services: Captains are Henry D’Atri (Manager Captain), Karen Siegler, Andrew Garcia and Carole Palmer. Accounting: Captains are Don Drake (Manager Captain) and Heather O’Connor.
5. Rules: NASD Rule 3011; Section 314 of the PATRIOT Act; 31 C.F.R. § 103.100.
   Resources: www.fincen.gov/314a_announcement021203.pdf;
   www.fincen.gov/314a_pressrelease02062003.pdf; NASD Member Alert (2/14/03).
   Rules: NASD Rule 3011; Section 314 of the PATRIOT Act; 31 C.F.R. § 103.19; 31 C.F.R. § 103.110.
   Other Resources: The notice form can be found at http://www.fincen.gov
6. Other Resources: NtM 02-21, page 6, n.24; SDN List- http://www.treas.gov/ofac/t11sdn.pdf.
   The OFAC Web site –– http://www.treas.gov/ofac/t11facsc.pdf –– contains checklists and information for securities firms to follow in checking the SDN List. You can subscribe to receive updates at http://www.treas.gov/press/email/subscribe.html. NASD provides a search engine to automate SDN List searches at http://www.nasdr.com/ofac/ Blocked Properties Reporting Form -- http://www.treas.gov/offices/enforcement/ofac/
   legal/forms/td902250.pdf. Voluntary Form for Reporting Blocked Transactions – http://www.treas.gov/offices/enforcement/ofac/
   legal/forms/e_blockreport1.pdf. Voluntary Form for Reporting Rejected Transactions – http://www.treas.gov/offices/enforcement/ofac/
   legal/forms/e_recjectreport1.pdf.
7. Rules: NASD Rule 3011; Section 326 of the PATRIOT Act; 31 C.F.R. §§ 103.122 et seq.
   Other Resources: NtM 02-21, page 6, n.24; 31 C.F.R. §§ 103.122. Rule: 31 C.F.R.
   § 103.122(g). Rule: 31 C.F.R. §§ 103.122 et seq.
8. Rules: NASD Rule 3011; Section 313 of the PATRIOT Act; 31 C.F.R. §§ 103.175 et
   seq. Rules: NASD Rule 3011; Section 313 of the PATRIOT Act; 31 C.F.R. §§ 103.175
   et seq. Rules: NASD Rule 3011; Sections 313 and 319 of the PATRIOT Act; 31 C.F.R.
   §§ 103.175, 177. Rules: NASD Rule 3011; Sections 313 and 319 of the PATRIOT Act;
   31 C.F.R. § 103.185.
9. Rules: NASD Rule 3011; Section 312 of the PATRIOT Act; 31 C.F.R. §§ 103.182.
   Other Resources: Guidance on Enhanced Scrutiny for Transactions that May Involve the Proceeds of Foreign Official Corruption - “Private Banking Activities” (June 30, 1997) which involve personalized services such as money management, financial advice, and investment services for high net worth clients etc, at http://www.federalreserve.gov/
   boarddocs/SRLETTERS/1997/SR9719.HTM
   Guidance on Enhanced Scrutiny of Transaction That May Involve Proceeds of Foreign Corruption – http://www.treas.gov/topics/law-enforcement/
10. Describe when and how your firm will call Federal law enforcement in emergencies.
    See: NtM 02-21, page 13. Other Resources: SDN List –– http://www.treas.gov/ofac/t11sdn.pdf.
11. Rules: NASD Rule 3011; Section 356 of the PATRIOT Act; 31 C.F.R. § 103.19.
    Other Resources: FinCEN’s Web Site contains additional information (See www.fincen.gov), including annual SAR Activity Reviews and SAR Bulletins, which discuss trends in suspicious reporting and give helpful tips. NtM 02-21page 12, n.38; NtM 02-47.
    SAR-SF Form (fill- in version) –– http://www.fincen.gov/fin101_
    formandinstructions.pdf –– http://www.fincen.gov/fin101_form_only.pdf SAR Activity Reviews –– http://www.fincen.gov/pub_main.html SAR Bulletins –– http://www.fincen.gov/pub_main.html Rules: 31 C.F.R. §§ 103.11, 103.22 Rules: 31 C.F.R. §§ 103.11, 103.23. Rules: 31 C.F.R. § 103.24. Rules: 31 C.F.R. § 103.33(f)
12. Rules: 31 C.F.R. § 103.19; 67 Fed. Reg. 126, 44501-44502 (July 1, 2002). See: NtM 02-21, page 14. Rules: NASD Rule 3011; 31 C.F.R. § 103.19; 31 C.F.R. § 103.33(f).
13. Rules: NASD Rule 3011; Sections 314(b) and 352 of the PATRIOT Act; Section 3.b. above.
14. Rules: NASD Rule 3011; Section 352 of the PATRIOT Act.
15. Rules: NASD Rule 3011; Section 352 of the PATRIOT Act.
16. Rules: NASD Rule 3011; Section 352 of the PATRIOT Act.
17. Rules: NASD Rule 3011; Section 352 of the PATRIOT Act.
18. Rules: NASD Rule 3011.

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