USA PATRIOT ACT

The USA Patriot Act, enacted in 2001, is designated to detect, deter and punish terrorists in the United States and abroad. The USA Patriot Act imposes new anti-money laundering requirements on brokerage firms and financial institutions. By April 24, 2002, all brokerage firms were required to have new, comprehensive anti-money laundering programs.

To help you understand these efforts, we want to provide you with some information about money laundering and our steps to implement the USA Patriots Act.

What is money laundering?

Money laundering is the process of disguising illegally obtained money so that the funds appear to come from legitimate sources of activities. Money laundering occurs in connection with a wide variety of crimes, including illegal arms sales; drug trafficking. robbery, fraud, racketeering, and terrorism.

How big is the problem and why is it important?

The use of the U.S. Financial system by criminals to facilitate terrorism or other crimes could well taint our financial markets. According to the U.S. State Department. one recent estimate puts the amount of worldwide money laundering activity at $1 trillion a year.

Our Commitment

Avalon Partners is committed to complying fully with all applicable law and regulation in relation to combating money laundering and any activity which facilitates the funding of terrorist or other criminal enterprises.

Bank Certification

As part of the national effort to combat money laundering and terrorist financing, the USA Patriot Act requires U.S. financial institutions to obtain certain information and certifications for accounts held by non-U.S. banks. These certifications must be obtained within 30 days of the opening of an account. If the documentation is not supplied in a timely manner, the account must be closed.

Banks covered by the rule include those organized under non-U.S. law, or an agency, branch or office located outside of the U.S. of a bank. The rule does not include any non U.S. central bank or monetary authority that functions as a central bank. Also excluded is any international financial institution or regional bank formed by treaty or international agreement.

To obtain the certificate that Avalon requires its non-U.S. bank customers to complete, please contact your account executive.

Please return your completed certificate to:

Avalon Partners
30 Broad Street
24th Floor
New York, NY 10004