Fill and Sign the Appendix I Department of Justice Form

-1- APPENDIX M Exhibit M FORM OF ANTI-MONEY LAUNDERING COMPLIANCE POLICY 1. Company Anti-Money Laundering Compliance Policy and ProgramIt is the policy of [X] (the "Company") that each employee, agent and officer comply with all anti-money laundering laws and regulations ("Anti-Money Laundering Compliance Policy or "Policy""). Pursuant to the Bank Secrecy Act ("BSA"), the Company has adopted policies, procedures and internal controls designed to prevent, detect and cause the reporting to appropriate authorities of any known or suspected money laundering, other criminal activity or suspicious transactions which together constitute the Company's "Anti-Money Laundering Compliance Program or Program". 1.1 Under the Program, the Company must:1.1.1 Appoint an Anti-Money Laundering Compliance Officer ("AML Compliance Officer"). 1.1.2 Implement such policies and procedures required for compliance with the BSA and the Office of Foreign Assets Control ("OFAC") regulations. 1.1.3 File a Suspicious Activity Report ("SAR") with respect to any known or suspected crime or suspicious transaction with the Treasury Department's Financial Crimes Enforcement Network (FinCEN). 1.1.4 Train relevant employees, including senior executives and directors on a regular basis. 1.1.5 Audit the Company's compliance with anti-money- laundering laws and regulations, this Policy and the Program. 1.2 The Policy requires that employees, agents and officers must;1.2.1 Comply with all anti-money laundering laws and regulations, including the record keeping and reporting requirements of the BSA. -2- 1.2.2 Accept only customers involved in legitimate business activities and whose income and wealth are derived from legitimate sources. 1.2.3 Adhere to the Company's "Know Your Customer" policies and procedures for account-opening and monitoring. 1.2.4 Refer suspicious activity to the AML Compliance Officer. 1.2.5 Cooperate with law enforcement authorities. Failure to comply with the BSA anti-money laundering laws may result in criminal and civil penalties and the forfeiture of property involved in or traceable to a money laundering transaction. Failure to comply with this Policy may result in disciplinary action, up to and including suspension or termination. 2. Anti-Money Laundering Compliance Officer ____________, is (are) the designated compliance person(s) AML Compliance Officer with responsibility for the Company's Anti-Money Laundering Compliance Program. Any questions regarding these procedures should be addressed to [him/her] (them). 2.1 The AML Compliance Officer is required to:2.1.1 Develop, implement and update appropriate anti- money laundering policies and procedures; including procedures for ensuring all required reports are made and all required records are maintained; 2.1.2 Provide ongoing training of relevant employees, including senior officers and directors; 2.1.3 Prepare, review and file Suspicious Activity Reports (SARs); 2.1.4 Monitor the day-to-day operations and implementation of the Program; 2.1.5 Report to the Company's governing board, senior management and chief compliance officer on BSA compliance issues and SARs. -3- Questions about the BSA anti-money laundering laws, this Policy or the Program should be addressed to the AML Compliance Officer. 3. The Bank Secrecy Act The BSA requires broker-dealers and other financial institutions to file reports and to maintain a variety of records for five years. Failure to comply can result in imprisonment, and criminal or civil money penalties. Among the most important BSA provisions are the following: 3.1 Currency Transaction Reports ("CTRs"). Financial institutions must file a CTR form for all transactions in currency conducted by, through or to the financial institution that results in deposits, withdrawals or transfers of more than $10,000 (U.S. or foreign currency) by or on behalf of the same person on the same business day. 3.1.1 Transactions of $10,000 or less by or on behalf of the same person which total more than $10,000 on the same business day must be reported if the financial institution knows that the transactions aggregate to an amount of more than $10,000. 3.1.2 Efforts to "structure" transactions to avoid this or any other required report violates federal law. Suspected structuring must be reported to a supervisor and the AML Compliance Officer. 3.1.3 If a client's physical currency transactions (other than transactions by means of bank check, wire transfer, or other written order) exceed this threshold , you must report the transactions to the Company's AML Compliance Officer no later than the close of business on the day on which the transaction or transactions occurred. 3.2 Currency or Monetary Instrument Reports. Subject to certain exceptions for broker-dealers, Reports of International Transportations of Currency or Monetary Instruments (CMIRs) are required to be filed with the U.S. Customs Service when any person (including an employee or customer) transports, mails or ships cash or travelers checks in any form or securities or negotiable instruments in bearer form that total more than $10,000 into or out of the U.S., or if they receive these instruments in the U.S. from outside the U.S. -4- 3.2.1 This rule does not apply to transactions which are shipped through the postal service or a common carrier such as UPS or Federal Express. 3.2.2 If a client engages in these type of transactions, you must notify the AML Compliance Officer of the transaction by the close of business on the day the transaction occurred. 3.3 Funds Transfers and Record Keeping Requirements. The BSA requires financial institutions, including brokers to keep a number of other records for five years. Detailed information also must be maintained about the originator or other transmitter and the beneficiary or other recipient of domestic and international funds transfers (wire transfers) of $3,000 or more. 3.3.1 The required information includes: (i) the names and addresses of both the transmitter and recipient of the funds; (ii) the identity of the recipient's financial institution, the account number to which the funds were transferred and the payment instructions. 3.3.2 If the Company is the transmitter's financial institution, the information must be included with the transmittal order and must be provided to the next bank or other financial institution in the payment process. 4. Know Your Customer: As part of its obligation to "Know Your Customer" ("KYC"), the Company is required to take certain steps in establishing and monitoring accounts. 4.1 Establishing an Account The account officer and the Account Opening Department, supervised by________, shall be jointly responsible to: 4.1.1 Make reasonable efforts to determine the true identity of all customers and legal and beneficial ownership of all accounts. -5- 4.1.2 No account should be opened for any individual unless the Company is confident of the client's identity, residence, source of funds and basic facts about the client and the client's objectives. This information should be fully documented on the new account form. 4.1.3 No account should be opened for an entity unless the Company obtains copies of all relevant documents relating to the formation of the entity and the identify of its senior officers, directors and agents authorized to use the account. 4.1.4 These documents should include a corporate charter or bylaws and a corporate resolution in the case of corporate entities, a partnership agreement for partnership accounts, trust agreements or certified copies of wills and relevant court orders for trusts and estate accounts. (See Chapter ___ of the Company's Supervisory Procedures for more information on required new account documentation.) 4.1.5 Screen the account for: