www.ipsaintl.com

Tel: 800-997-4772

IPSA International, Inc (IPSA)

is a leading global provider of

high-end investigative and

consulting services serving

the corporate, financial and

legal communities. IPSA's

preferred practice areas are:

Anti-Money Laundering,

Operational Risk,

Due Diligence,

Intellectual Property Protection

and Litigation Support.

ANTI-MONEY LAUNDERING

IPSA’s anti-money laundering (AML) experts provide a broad range of professional and consulting services designed to provide supplemental resources and expertise in a wide array of organizational structures and conditions, geographic markets and regulatory situations. IPSA’s objective with each client is to provide the most effective AML solution available or to deploy the resources necessary to successfully manage a specific event. IPSA’s primary AML services are outlined below.

Regulatory Directed Remediation Financial institutions are often faced with a regulatory directive (such as a cease and desist order) or are required to perform an intensive internal investigation, often with a very tight deadline. To address institutions’ needs, IPSA's team, consisting of former Federal agents, regulators, compliance officers and experienced bank professionals can be on-site within days of a regulatory incident. IPSA will assist the institution’s staff in the management of internal investigations, transactional analyses, review of CTR and SAR filings, drafting of reports and facilitation of communications with regulators and law enforcement officials to support a timely, organized institutional response.

Customer Identification Program The USA PATRIOT Act requires all U.S. financial institutions to implement a Customer Identification Program (CIP) and to perform Investigative Due Diligence on high risk accounts. Many financial institutions maintain a competent compliance staff that is able to perform general due diligence on its neutral-risk customers. However, complying with these requirements can be burdensome, time-consuming and costly. IPSA has developed CIP solutions to allow financial institutions to best focus on other compliance issues while still meeting their regulatory require-ments.Specially trained AML analysts perform reviews of customer identity documents, independently verify these documents using multiple sources and provide timely reports for each customer that can be used as supporting documentation for the customer’s file. IPSA offers a two-tiered pro-gram approach:

• Tier 1 Program: Designed to confirm customers’ personal identifiers, including current address(es) and tax numbers; screen customers against global sanctions and watch lists for pos-sible references; and research international newspaper and other media sources for derogatory reports.

• Tier 2 Program: Includes a review of criminal history, litigation history, bankruptcy, tax and other legally imposed financial obligations involving the customer. Tier 2 can also complement a Tier 1 inquiry and resolve any alerts that may have been surfaced by the initial check.

Know Your Customer (KYC) & Enhanced Due Diligence (EDD) ServicesHigh risk accounts require a more thorough review or EDD. The most effective manner to conduct appropriate due diligence relies upon independent, third party sources that can validate the customer’s identifiers and undertake the proper investigative activities in the required jurisdictions in order to provide a detailed report in a timely manner. Utilizing a vast network of associates in over 100 countries IPSA’s EDD investigates:

• Complete public database query • Banking licenses • Comprehensive media search • Judicial antecedents • In-country retrieval and examination • Contact with local banking, government, of personal identifiers business and legal sources • Corporate by-laws

Intelligence at Work®

• T

Intelligence at Work®PRacticE Areas

• Anti-Money Laundering

• Operational Risk

• Due Diligence

• Intellectual Property Protection

• Litigation Support

For more information about IPSA International Inc . , cal l us at 800-997-4772 or vis it our web s ite at www.ipsaintl .com© IPSA International, 2010. All Rights Reserved.

Rev. in 09/10

www.ipsaintl.com

Tel: 800-997-4772

IPSA’s investigative expertise and global network of intelligence sources have particular strength in emerging markets such as Latin America, Russia and China. This allows our AML professionals to obtain, corroborate and/or verify KYC and critical EDD information globally to minimize an institution’s risks and ensure compliance with USA PATRIOT Act and BSA requirements.

AML Compliance Program ConsultingIPSA assists our clients by helping them define the policies, standards, roles and responsibilities necessary to implement an effective AML program. IPSA can also evaluate revisions or alternatives to an institution’s existing AML program and its components. Additionally, IPSA professionals can support the compliance function by conducting an independent risk survey that identifies the institution’s most significant regulatory risks.

Suspicious Activity InvestigationsIPSA’s AML, investigative professionals bring the regulatory and law enforcement expertise and experience needed to assist the client in taking affirmative steps to avoid (or where required) address negative regulatory findings. IPSA’s involvement in an investigation facilitates a coordinated review and inquiry into specific situations that are or may pose a risk. IPSA is able to apply extensive experience and a global network of information sources to manage almost any investigative situation.

Independent Assessments IPSA’s professionals can assist a financial institution’s audit function by providing the expertise required in examining the compliance function, with or without the support of internal staff. IPSA can also help conduct an assessment or pre-exam review of an AML compliance program in the context of a pending merger or regulatory examination, thus enhancing senior management’s knowledge and confidence during such situations. In addition, IPSA can help supplement an institution’s testing capabilities with ad hoc or periodic reviews designed to review compliance with its AML program.

Firm ProfileIPSA International is an independent risk advisory firm providing clients in the financial, corporate and legal communities with high-end investigative and consulting services. Specializing in the areas of Anti-Money Laundering, Operational Risk, Due Diligence, Intellectual Property Protection and Litigation Support, IPSA assist clients in mitigating and or responding to potential legal, financial and reputational risks. IPSA International, Inc. takes pride in building long-term relationships with our clients, as we never forget the importance of Managing the Balance Between Risk and Reward©.

To obtain more information regarding our anti-money laundering and risk advisory services, please contact IPSA International at 800-997-4772 or visit us online www.ipsaintl.com

ANTI-MONEY LAUNDERING continued...