The AmeriCorp Group of Companies. ("ACG") and each of its majority-owned subsidiaries are firmly committed to participating in international efforts to combat money laundering and the funding of terrorist activities.

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ACG is a registered holding company headquartered in Orange County, California in the United States ("U.S."). The Firm is also regulated by various U.S. federal and securities regulators and other regulatory organizations, including self-regulatory organizations, as well as other U.S. and non-U.S. governmental agencies that have supervisory authority over certain legal entities in those jurisdictions where the Firm operates.

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The Firm has implemented a risk-based global Anti-Money Laundering ("AML") Compliance Program ("AML Program") designed to comply with AML laws and regulations in the U.S., including the Bank Secrecy Act, as amended by the USA PATRIOT Act of 2001, and other applicable laws and regulations relating to the prevention of money laundering and terrorist financing in the jurisdictions where the Firm operates.

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The Firm has established a Global Sanctions Compliance Program ("GSC Program") consisting of the following elements: (i) procedures, systems, and internal controls designed to comply with applicable sanctions;(ii) a designated person responsible for the day-to-day implementation and operation of the GSC Program; (iii) independent testing; (iv) an ongoing training program; and (v) reporting and record keeping. GSC is headed by the Director of Global Sanctions Compliance who is designated by the Head of Global Financial Crimes Compliance.