1. ENTITY & OWNERSHIP - Wolfsberg Group

1 Wolfsberg Group Financial Crime Compliance Questionnaire (FCCQ) Institution Name:Location (Country) : The Wolfsberg Group 2020 Page 1 FCCQ #QuestionAnswer1. ENTITY & OWNERSHIP1 Full Legal name2 Append a list of foreign branches which arecovered by this questionnaire (if applicable)3 Full Legal (Registered) Address4 Full Primary Business Address (if different fromabove)5 Date of ENTITY incorporation / establishment6 Select type of OWNERSHIP and append anownership chart if available6 aPublicly Traded (25% of shares publicly traded)6 a1If Y, indicate the exchange traded on and tickersymbol6 bMember Owned / Mutual6 cGovernment or State Owned by 25% or more6 dPrivately Owned6 d1If Y, provide details of shareholders or ultimatebeneficial owners with a holding of 10% or more7% of the ENTITY 's total shares composed ofbearer shares8 Does the ENTITY , or any of its branches, operateunder an Offshore Banking License (OBL) ?

2 8 aIf Y, provide the name of the relevant branch/eswhich operate under an OBLW olfsberg Group Financial Crime Compliance Questionnaire (FCCQ) The Wolfsberg Group 2020 Page 2 FCCQ AML, CTF & SANCTIONS PROGRAMME9 Does the ENTITY have a programme that setsminimum AML, CTF and Sanctions standards regarding the following components:9 aAppointed Officer with sufficient experience /expertise9 bCash Reporting9 cCDD9 dEDD9 eBeneficial Ownership9 fIndependent Testing9 gPeriodic Review9 hPolicies and Procedures9 iRisk Assessment9 jSanctions9 kPEP Screening9 lAdverse Information Screening9 mSuspicious Activity Reporting9 nTraining and Education9 oTransaction Monitoring10Is the ENTITY 's AML, CTF & Sanctions policyapproved at least annually by the Board or equivalent Senior Management Committee?11 Does the ENTITY use third parties to carry out anycomponents of its AML, CTF & Sanctions programme?

3 11aIf Y, provide further detailsWolfsberg Group Financial Crime Compliance Questionnaire (FCCQ) The Wolfsberg Group 2020 Page 3 FCCQ ANTI BRIBERY & CORRUPTION12 Has the ENTITY documented policies andprocedures consistent with applicable ABC regulations and requirements to [reasonably] prevent, detect and report bribery and corruption?13 Does the ENTITY 's internal audit function or otherindependent third party cover ABC Policies and Procedures?14 Does the ENTITY provide mandatory ABC trainingto:14 aBoard and Senior Committee Management14 b1st Line of Defence14 c2nd Line of Defence14 d3rd Line of Defence14 e3rd parties to which specific complianceactivities subject to ABC risk have been outsourced14 fNon-employed workers as appropriate(contractors / consultants) Wolfsberg Group Financial Crime Compliance Questionnaire (FCCQ) The Wolfsberg Group 2020 Page 4 FCCQ AML, CTF & SANCTIONS POLICIES & PROCEDURES15 Has the ENTITY documented policies andprocedures consistent with applicable AML, CTF & Sanctions regulations and requirements to reasonably prevent, detect and report:15 aMoney laundering15 bTerrorist financing15 cSanctions violations16 Does the ENTITY have policies and proceduresthat.

4 16 aProhibit the opening and keeping of anonymousand fictitious named accounts16 bProhibit the opening and keeping of accounts forunlicensed banks and / or NBFIs16 cProhibit dealing with other entities that providebanking services to unlicensed banks16 dProhibit accounts / relationships with shell banks16 eProhibit dealing with another ENTITY that providesservices to shell banks16 fProhibit opening and keeping of accounts forSection 311 designated entities16 gProhibit opening and keeping of accounts forany of unlicensed / unregulated remittance agents, exchanges houses, casa de cambio, bureaux de change or money transfer agents16 hAssess the risks of relationships with domesticand foreign PEPs, including their family and close associates16 iDefine escalation processes for financial crimerisk issues16 jSpecify how potentially suspicious activityidentified by employees is to be escalated and investigated16 kOutline the processes regarding screening forsanctions, PEPs and negative media17 Has the ENTITY defined a risk tolerance statementor similar document which defines a risk boundary around their business?

5 18 Does the ENTITY have a record retentionprocedures that comply with applicable laws?18 aIf Y, what is the retention period? Wolfsberg Group Financial Crime Compliance Questionnaire (FCCQ) The Wolfsberg Group 2020 Page 5 FCCQ KYC, CDD and EDD19 Does the ENTITY verify the identity of thecustomer?20Do the ENTITY 's policies and procedures set outwhen CDD must be completed, at the time of onboarding or within 30 days21 Which of the following does the ENTITY gatherand retain when conducting CDD? Select all that apply:21 aOwnership structure21 bCustomer identification21 cExpected activity21 dNature of business / employment21 eProduct usage21 fPurpose and nature of relationship21 gSource of funds21 hSource of wealth22 Are each of the following identified:22 aUltimate beneficial ownership22 a1 Are ultimate beneficial owners verified?22 bAuthorised signatories (where applicable)22 cKey controllers22 dOther relevant parties23 Does the due diligence process result incustomers receiving a risk classification?

6 24 Does the ENTITY have a risk based approach toscreening customers and connected parties to determine whether they are PEPs, or controlled by PEPs?25 Does the ENTITY have policies, procedures andprocesses to review and escalate potential matches from screening customers and connected parties to determine whether they are PEPs, or controlled by PEPs?26 Does the ENTITY have a process to review andupdate customer information based on:26 aKYC renewal26 bTrigger eventWolfsberg Group Financial Crime Compliance Questionnaire (FCCQ) The Wolfsberg Group 2020 Page 6 FCCQ the list below, which categories ofcustomers or industries are subject to EDD and/ or are restricted, or prohibited by the ENTITY 's FCC programme?27 aNon-account customers27 bNon-resident customers27 cShell banks27 dMVTS/ MSB customers27 ePEPs27 fPEP Related27 gPEP Close Associate27 hCorrespondent Banks27 h1If EDD or EDD & restricted, does the EDDassessment contain the elements as set out in the Wolfsberg Correspondent Banking Principles 2014?

7 27 iArms, defense, military27 jAtomic power27 kExtractive industries27 lPrecious metals and stones27 mUnregulated charities27 nRegulated charities27 oRed light business / Adult entertainment27 pNon-Government Organisations27 qVirtual currencies27 rMarijuana27 sEmbassies / Consulates27 tGambling27 uPayment Service Provider27 vOther (specify)28If restricted, provide details of the restrictionWolfsberg Group Financial Crime Compliance Questionnaire (FCCQ) The Wolfsberg Group 2020 Page 7 FCCQ MONITORING & REPORTING29 Does the ENTITY have risk based policies,procedures and monitoring processes for the identification and reporting of suspicious activity?30 What is the method used by the ENTITY tomonitor transactions for suspicious activities?31 Does the ENTITY have regulatory requirements toreport suspicious transactions?31 aIf Y, does the ENTITY have policies, proceduresand processes to comply with suspicious transactions reporting requirements?

8 32 Does the ENTITY have policies, procedures andprocesses to review and escalate matters arising from the monitoring of customer transactions and activity? Wolfsberg Group Financial Crime Compliance Questionnaire (FCCQ) The Wolfsberg Group 2020 Page 8 FCCQ PAYMENT TRANSPARENCY33 Does the ENTITY adhere to the Wolfsberg GroupPayment Transparency Standards?34 Does the ENTITY have policies, procedures andprocesses to [reasonably] comply with and have controls in place to ensure compliance with:34 aFATF Recommendation 1634 bLocal Regulations34 b1 Specify the regulation34 cIf N, explainWolfsberg Group Financial Crime Compliance Questionnaire (FCCQ) The Wolfsberg Group 2020 Page 9 FCCQ SANCTIONS35 Does the ENTITY have policies, procedures orother controls reasonably designed to prohibit and / or detect actions taken to evade applicable sanctions prohibitions, such as stripping, or the resubmission and / or masking, of sanctions relevant information in cross border transactions?

9 36 Does the ENTITY screen its customers, includingbeneficial OWNERSHIP information collected by the ENTITY , during onboarding and regularly thereafter against Sanctions Lists?37 Select the Sanctions Lists used by the ENTITY inits sanctions screening processes:37 aConsolidated United Nations Security CouncilSanctions List (UN)37 bUnited States Department of the Treasury'sOffice of Foreign Assets Control (OFAC)37 cOffice of Financial Sanctions ImplementationHMT (OFSI)37 dEuropean Union Consolidated List (EU)37 eLists maintained by other G7 member countries37 fOther (specify)38 Does the ENTITY have a physical presence, ,branches, subsidiaries, or representative offices located in countries / regions against which UN, OFAC, OFSI, EU and G7 member countries have enacted comprehensive jurisdiction-based Sanctions? Wolfsberg Group Financial Crime Compliance Questionnaire (FCCQ) The Wolfsberg Group 2020 Page 10 FCCQ TRAINING & EDUCATION39 Does the ENTITY provide mandatory training,which includes :39 aIdentification and reporting of transactions togovernment authorities39 bExamples of different forms of moneylaundering, terrorist financing and sanctions violations relevant for the types of products and services offered39 cInternal policies for controlling moneylaundering, terrorist financing and sanctions violations39 dNew issues that occur in the market, ,significant regulatory actions or new regulations40Is the above mandatory training provided to.

10 40 aBoard and Senior Committee Management40 b1st Line of Defence40 c2nd Line of Defence40 d3rd Line of Defence40 e3rd parties to which specific FCC activities havebeen outsourced40 fNon-employed workers (contractors /consultants) Wolfsberg Group Financial Crime Compliance Questionnaire (FCCQ) The Wolfsberg Group 2020 Page 11 FCCQ AUDIT41In addition to inspections by the governmentsupervisors / regulators, does the ENTITY have an internal audit function, a testing function or other independent third party, or both, that assesses FCC AML, CTF and Sanctions policies and practices on a regular basis?_____Wolfsberg Group Financial Crime Compliance Questionnaire (FCCQ) PageWolfsberg Group Financial Crime Compliance Questionnaire 2020 (FCCQ )(Financial Institution name)I, (Senior Compliance Manager- Second Line representative), certify that I have read and understood thisdeclaration, that the answers provided in this Wolfsberg FCCQ are complete and correct to my honest belief.