A - Client/Customer Risk NB. For Purposes Of This Form .

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IntroductionThe AML/CFT Inherent Risks - Securities form (AIR-157-75) is to be completed by every Securities Investment Business – Excluded Persons (who is commonlyreferred to as "entity" for purposes of this form) in REEFS, via its registered office, on or before 15 August 2019.A - Client/Customer RiskNB. For purposes of this form, "client" and "customer" are used interchangeably, and relate to anyone with or for whom securities investmentbusiness is transacted.A - Client/Customer RiskHow many clients/customers does the entity have in total?This section represents an aggregate for all clients/customers that theentity provides any securities investment business services to.Number of Clients/CustomersThis number should total all active clients/customers the entityprovides securiteis investment business services to as opposed toaccounts (I.E. If the same client (individual or legal entity) has twoaccounts in the same name, then only 1 should be counted. Do notdouble count.)A01bGeographyAll jurisdictions where each client/customer in this category isdomiciled should be selected in this category. The dropdown signto the left hand side of the page, allow the entity to insertmultiple jurisdictions when more than one is applicable for thiscategory, throughout this form.A01oWhat is the total value of assets under management within the past12 months?Insert the US dollar value amount for all assets under managementheld by the entity as at 30 June 2019. If the entity does not manageassets for its clients/customers, 0 should be inserted.A02-A12All of the clients/customers categorized in A02-A12 are to total all active clients disclosed in A01a above.A01A01aGovernment/Public SectorThis category includes central government units that exists at eachlevel – Federal, State or Local government within the nationaleconomy and Central Banks / Monetary Authorities; as well as PublicFinancial Corporations and Public Non-Financial Corporationscontrolled by the Government (excluding Central Banks and MonetaryAuthorities).A02aNumber of Transactions CompletedThis is to be an aggregate of all transactions conducted forclients/customers in this category from 30 June 2018 to 30 June2019. (I.E. If 1 order to trade a security at a specific price is filledover several lots, it is to be counted as a single transaction.)A02bValue of Assets Held Under Management for This CategoryClient/CustomerThis is the account value range for all clients/customers in thiscategory as at 30 June 2019.A02cNumber of Clients/CustomersThis number should total all active clients/customers in this category.Clients/customers where business relationships have ceased, shouldnot be included.A02dGeographyAll jurisdictions where each client/customer in this category isdomiciled should be selected in this category (I.E. The dropdownallows for multiple jurisdictions to be selected).A03Non-Profit OrganizationsThis category includes charities and organizations that do notdistribute income to is shareholders or members using incomegenerated from its objectives.A03aNumber of Transactions CompletedThis is to be an aggregate of all transactions conducted forclients/customers in this category from 30 June 2018 to 30 June2019. (I.E. If 1 order to trade a security at a specific price is filledover several lots, it is to be counted as a single transaction.)A03bValue of Assets Held Under Management for This CategoryClient/CustomerThis is the account value range for all clients/customers in thiscategory as at 30 June 2019.A03cNumber of Clients/CustomersThis number should total all active clients/customers in this category.Clients/customers where business relationships have ceased, shouldnot be included.GeographyAll jurisdictions where each client/customer in this category isdomiciled should be selected in this category (I.E. The dropdownallows for multiple jurisdictions to be selected).Financial InstitutionsThis category includes banks, insurance companies, investmentcompanies or some type of company engaged in the business ofdealing with financial and monetary transactions such as deposits,loans, investments or currency exchanges. NB. Do not include trustcompanies in this section, although it can be considered afinancial institution.A02A03dA04

A04aNumber of Transactions CompletedThis is to be an aggregate of all transactions conducted forclients/customers in this category from 30 June 2018 to 30 June2019. (I.E. If 1 order to trade a security at a specific price is filledover several lots, it is to be counted as a single transaction.)A04bValue of Assets Held Under Management for This CategoryClient/CustomerThis is the account value range for all clients/customers in thiscategory as at 30 June 2019.A04cNumber of Clients/CustomersThis number should total all active clients/customers in this category.Clients/customers where business relationships have ceased, shouldnot be included.A04dGeographyAll jurisdictions where each client/customer in this category isdomiciled should be selected in this category (I.E. The dropdownallows for multiple jurisdictions to be selected).Non-Financial InstitutionsThis category includes private commercial non-financial corporations,such as construction companies, hotels, restaurants, retailers andwholesalers. Designated non-financial busines and profession can alsobe accounted for in this category.A05aNumber of Transactions CompletedThis is to be an aggregate of all transactions conducted forclients/customers in this category from 30 June 2018 to 30 June2019. (I.E. If 1 order to trade a security at a specific price is filledover several lots, it is to be counted as a single transaction.)A05bValue of Assets Held Under Management for This CategoryClient/CustomerThis is the account value range for all clients/customers in thiscategory as at 30 June 2019.A05cNumber of Clients/CustomersThis number should total all active clients/customers in this category.Clients/customers where business relationships have ceased, shouldnot be included.A05dGeographyAll jurisdictions where each client/customer in this category isdomiciled should be selected in this category (I.E. The dropdownallows for multiple jurisdictions to be selected).IndividualsThis category solely related to a human being, as distinguished from acompany or other entity created by operation of law with separatelegal personality. If the account is held in the name(s) of more thanone individual (i.e. joint account), it should be captured in thiscategory.A06aNumber of Transactions CompletedThis is to be an aggregate of all transactions conducted forclients/customers in this category from 30 June 2018 to 30 June2019. (I.E. If 1 order to trade a security at a specific price is filledover several lots, it is to be counted as a single transaction.)A06bValue of Assets Held Under Management for This CategoryClient/CustomerThis is the account value range for all clients/customers in thiscategory as at 30 June 2019.A06cNumber of Clients/CustomersThis number should total all active clients/customers in this category.Clients/customers where business relationships have ceased, shouldnot be included.A06dGeographyAll jurisdictions where each client/customer in this category isdomiciled should be selected in this category (I.E. The dropdownallows for multiple jurisdictions to be selected).CorporatesThis category relates to companies (exempt, limited,ordinary/resident, international business), partnerships (general,limited, exempt), foreign that are incorporated under the laws of theIslands or under the laws of any other country or place. NB. Do notinclude corporates in this section, if they have already beencategorized in one of other categories in this section of theform (i.e. trusts and financial institutions).A07aNumber of Transactions CompletedThis is to be an aggregate of all transactions conducted forclients/customers in this category from 30 June 2018 to 30 June2019. (I.E. If 1 order to trade a security at a specific price is filledover several lots, it is to be counted as a single transaction.)A07bValue of Assets Held Under Management for This CategoryClient/CustomerThis is the account value range for all clients/customers in thiscategory as at 30 June 2019.A07cNumber of Clients/CustomersThis number should total all active clients/customers in this category.Clients/customers where business relationships have ceased, shouldnot be included.A07dGeographyAll jurisdictions where each client/customer in this category isdomiciled should be selected in this category (I.E. The dropdownallows for multiple jurisdictions to be selected).A08TrustsThis category includes any type of legal structure that carries on trustbusiness.Number of Transactions CompletedThis is to be an aggregate of all transactions conducted forclients/customers in this category from 30 June 2018 to 30 June2019. (I.E. If 1 order to trade a security at a specific price is filledover several lots, it is to be counted as a single transaction.)A05A06A07A08a

A08bValue of Assets Held Under Management for This CategoryClient/CustomerThis is the account value range for all clients/customers in thiscategory as at 30 June 2019.A08cNumber of Clients/CustomersThis number should total all active clients/customers in this category.Clients/customers where business relationships have ceased, shouldnot be included.A08dGeographyAll jurisdictions where each client/customer in this category isdomiciled should be selected in this category (I.E. The dropdownallows for multiple jurisdictions to be selected).A09NomineesThis category includes any person or legal structure who is obtainngservices on behalf of another person. (I.E. Trustee, executor,administrator, legal structures acting on behalf of someone else).A09aNumber of Transactions CompletedThis is to be an aggregate of all transactions conducted forclients/customers in this category from 30 June 2018 to 30 June2019. (I.E. If 1 order to trade a security at a specific price is filledover several lots, it is to be counted as a single transaction.)A09bValue of Assets Held Under Management for This CategoryClient/CustomerThis is the account value range for all clients/customers in thiscategory as at 30 June 2019.A09cNumber of Clients/CustomersThis number should total all active clients/customers in this category.Clients/customers where business relationships have ceased, shouldnot be included.A09dGeographyAll jurisdictions where each client/customer in this category isdomiciled should be selected in this category (I.E. The dropdownallows for multiple jurisdictions to be selected).A10Special Purpose VehiclesThis category includes legal structures that are incorporated as aspecial purpose vehicle for asset acquisition, leasing andsecuritization.A10aNumber of Transactions CompletedThis is to be an aggregate of all transactions conducted forclients/customers in this category from 30 June 2018 to 30 June2019. (I.E. If 1 order to trade a security at a specific price is filledover several lots, it is to be counted as a single transaction.)A10bValue of Assets Held Under Management for This CategoryClient/CustomerThis is the account value range for all clients/customers in thiscategory as at 30 June 2019.A10cNumber of Clients/CustomersThis number should total all active clients/customers in this category.Clients/customers where business relationships have ceased, shouldnot be included.A10dGeographyAll jurisdictions where each client/customer in this category isdomiciled should be selected in this category (I.E. The dropdownallows for multiple jurisdictions to be selected).A11Special Economic ZoneThis category includes any type of entity authorized to be carried onin a special economic zone pursuant to any law in force in the Islands.A11aNumber of Transactions CompletedThis is to be an aggregate of all transactions conducted forclients/customers in this category from 30 June 2018 to 30 June2019. (I.E. If 1 order to trade a security at a specific price is filledover several lots, it is to be counted as a single transaction.)A11bValue of Assets Held Under Management for This CategoryClient/CustomerThis is the account value range for all clients/customers in thiscategory as at 30 June 2019.A11cNumber of Clients/CustomersThis number should total all active clients/customers in this category.Clients/customers where business relationships have ceased, shouldnot be included.A11dGeographyAll jurisdictions where each client/customer in this category isdomiciled should be selected in this category (I.E. The dropdownallows for multiple jurisdictions to be selected).A12OtherThis category is to be completed if a client/customer does not fallwithin any one of the categories referenced above.A12aSpecifyEnter the name of the category for any clients/customers that do notfall within any one of the categories referenced above.A12bNumber of Transactions CompletedThis is to be an aggregate of all transactions conducted forclients/customers in this category from 30 June 2018 to 30 June2019. (I.E. If 1 order to trade a security at a specific price is filledover several lots, it is to be counted as a single transaction.)A12cValue of Assets Held Under Management for This CategoryClient/CustomerThis is the account value range for all clients/customers in thiscategory as at 30 June 2019.

A12dNumber of Clients/CustomersThis number should total all active clients/customers in this category.Clients/customers where business relationships have ceased, shouldnot be included.A12eGeographyAll jurisdictions where each client/customer in this category isdomiciled should be selected in this category (I.E. The dropdownallows for multiple jurisdictions to be selected).A13How many of the clients/customers are High Net Worth (HNW)Individuals - with a net worth of at least CI 800,000.See definition of HNW Individual in the Securities InvestmentBusiness Law (2019 Revision).A13aNumber of Transactions CompletedThis is to be an aggregate of all transactions conducted forclients/customers in this category from 30 June 2018 to 30 June2019. (I.E. If 1 order to trade a security at a specific price is filledover several lots, it is to be counted as a single transaction.)A13bValue of Assets Held Under Management for This CategoryClient/CustomerThis is the account value range for all clients/customers in thiscategory as at 30 June 2019.A13cNumber of Clients/CustomersThis number should total all active clients/customers in this category.Clients/customers where business relationships have ceased, shouldnot be included. NB. Do not include HNW Individuals that arealso sophisticated in this total as such information should becaptured in A16.A13dGeographyAll jurisdictions where each client/customer in this category isdomiciled should be selected in this category (I.E. The dropdownallows for multiple jurisdictions to be selected).A14HNW Persons - with total assets of not less than CI 4,000,000See definition of HNW Person in the Securities Investment BusinessLaw (2019 Revision)(the "SIBL").A14aNumber of Transactions CompletedThis is to be an aggregate of all transactions conducted forclients/customers in this category from 30 June 2018 to 30 June2019. (I.E. If 1 order to trade a security at a specific price is filledover several lots, it is to be counted as a single transaction.)A14bValue of Assets Held Under Management for This CategoryClient/CustomerThis is the account value range for all clients/customers in thiscategory as at 30 June 2019.Number of Clients/CustomersThis number should total all active clients/customers in this category.Clients/customers where business relationships have ceased, shouldnot be included. NB. Do not include HNW Persons that are alsosophisticated in this total as such information should becaptured in A16.A14dGeographyAll jurisdictions where each client in this category is domiciled shouldbe selected in this category (I.E. The dropdown allows for multiplejurisdictions to be selected).A15Sophisticated PersonSee definition of sophisticated person in the SIBL.A15aNumber of Transactions CompletedThis is to be an aggregate of all transactions conducted for clients inthis category from 30 June 2018 to 30 June 2019. (I.E. If 1 order totrade a security at a specific price is filled over several lots, it is to becounted as a single transaction.)A15bValue of Assets Held Under Management for This CategoryClient/CustomerThis is the account value range for all clients/customers in thiscategory as at 30 June 2019.A15cNumber of Clients/CustomersThis number should total all active clients/customers in this category.Clients where business relationships have ceased, should not beincluded. NB. This total relates to sophisticated clients only. Donot include HNW Persons that are also sophisticated in thistotal.A15dGeographyAll jurisdictions where each client/customer in this category isdomiciled should be selected in this category (I.E. The dropdownallows for multiple jurisdictions to be selected).A16HNW and Sophisticated PersonsA14cA16aNumber of Transactions CompletedThis is to be an aggregate of all transactions conducted forclients/customers in this category from 30 June 2018 to 30 June2019. (I.E. If 1 order to trade a security at a specific price is filledover several lots, it is to be counted as a single transaction.)A16bValue of Assets Held Under Management for This CategoryClient/CustomerThis is the account value range for all clients/customers in thiscategory as at 30 June 2019.A16cNumber of Clients/CustomersThis number should total all active clients/customers in this category.Clients where business relationships have ceased, should not beincluded. NB. Do not include HNW Individuals and Persons thatwere included in section A13, A14 or A15 as this total relatesonly to individuals and persons that are both HNW andsophisticated.A16dGeographyAll jurisdictions where each client/customer in this category isdomiciled should be selected in this category (I.E. The dropdownallows for multiple jurisdictions to be selected).

Politically Exposed PersonsSee part II - section 7 of the Guidance Notes on the Prevention andDetection of Money Laundering and Terrorist Financing in the CaymanIslands, December 2017 ("AML Guidance Notes") to see whoconstitutes as a Potically Exposed Person. Include allindividuals/persons that have been previously categoried in sectionsA01, A02c-A16c above.A17aNumber of Transactions CompletedThis is to be an aggregate of all transactions conducted forclients/customers in this category from 30 June 2018 to 30 June2019. (I.E. If 1 order to trade a security at a specific price is filledover several lots, it is to be counted as a single transaction.)A17bValue of Assets Held Under Management for This CategoryClient/CustomerThis is the account value range for all clients/customers in thiscategory as at 30 June 2019.A17cNumber of Clients/CustomersThis number should total all active clients in this category.Clients/customers where business relationships have ceased, shouldnot be included. NB. This total is to include all clients that theentity provides securities investment business services to.A17dGeographyAll jurisdictions where each client/customer in this category isdomiciled should be selected in this category (I.E. The dropdownallows for multiple jurisdictions to be selected).A18What percentage of the entity's client/customer base is consideredHNW?Select most suitable percentage category which denotes only HNWindividuals and persons of the entity's total client/customerpopulation.A19What percentage of the entity's client/customer base is consideredsophisticated?Select most suitable percentage category which denotes onlysophisticated persons of the entity's total client/customer population.A20What percentage of the entity's clients/customers are consideredHNW and sophisticated? (Do not double count)Select most suitable percentage category which denotes only HNWindividuals, HNW persons and sophisticated persons of the entity'stotal client/customer population

dealing with financial and monetary transactions such as deposits, loans, investments or currency exchanges. NB. Do not include trust companies in this section, although it can be considered a financial institution. All of the clients/customers categorized in A02-A12 are to total all active clients disclosed in A01a above. Introduction

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