Due Diligence Report & Anti Money Laundering Questionnaire GENERAL INFORMATION

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1 GENERAL INFORMATION Institution Name: Regulator: License Type: Banking License Number: Commercial Registration #: Company Type: SWIFT Number: Registered Address: ALUBAF Arab International Bank B.S.C Central Bank of Bahrain (CBB) Wholesale Bank WB/01 Stock Holding Company Closed ALUBBHBM Alubaf Tower, Building 854, Road 3618, Avenue 436, Al Seef District, Manama- Kingdom of Bahrain. Postal Address: P.O Box: Manama - Kingdom of Bahrain Web Address: Telephone Number: (+) Fax Number: (+) Name of External Auditors: Ernst & Young

2 ALUBAF ARAB INTERNATIONAL BANK AML POLICY Background ALUBAF Arab International Bank B.S.C. ("ALUBAF") is a closed Bahraini joint stock company incorporated in the Kingdom of Bahrain and registered with the Ministry of Industry and Commerce under Commercial Registration (CR) number The bank operates under a wholesale banking license issued by the Central Bank of Bahrain (CBB) under license number WB/01. Anti Money Laundering Regulations The Kingdom of Bahrain s has primary legislation relevant to prevention and prohibition of the money laundering and combating the financing of terrorism. The regulation implemented by the CBB is in compliance with the Financial Action Task Force (FATF). The Financial Crime regulations demonstrated the FATF 40 Recommendations on money laundering and 9 Special Recommendations on terrorism financing provide the most widely recognized standards. The kingdom of Bahrain s legislation relevant to AML/CFT can be accessed on the CBB website Anti Money Laundering Policy ALUBAF s Bank anti money laundering (AML) policy intended to ensure that the Bank has a comprehensive framework of policies and procedures including best practice standards for combating money laundering and terrorist financing. The

3 policies and procedures are anticipated to prevent the Bank s operations activities from being used by others for unlawful purposes. The bank s policy prohibit and actively prevent money laundering and any activity that facilitate money laundering or funding of terrorist or criminal activities by comply with the AML laws and regulations of the jurisdiction in which it undertakes business activities and as per compliance program. Customer due Diligence ALUBAF s Bank would not establish a new business relationship or provide financial services until appropriate customer due diligence (CDD) are taken and recorded by obtaining counterparty identity documents. The KYC documents and information are required to be obtained prior to commencing the relationship in order to obtain sufficient information related the counterparty and satisfied that the customer and their business are legitimate and the Bank is not at risk of financial loss or a damaged reputation. The KYC information includes, but not limited to personal details; type of business activity; date and place of incorporation; regulatory or listing body; name of external auditor ;and type of account and nature and level of business relationship with the bank and information concerning the source of income. Reporting of Suspicious Circumstances Any suspicious circumstances surrounding the opening or operation of any account, the matter must be reported immediately to the Money Laundering

4 Reporting Officer (MLRO) using the suspicious Transaction Internal Report for validation by MLRO and reporting to an appropriate authorities. The reporting of suspicious transactions are the duty of every member of the management and staff to report toward MLRO. Retention of Records The bank will keep an adequate records and identification documents for at least five years from the end of the banks relationship with the customer or from the date when the transaction was completed. Training The Bank committed to provide periodic training and information to ensure that all affected employees are aware of their responsibilities under the AML law and CBB regulation. The bank provide up to date AML training for relevant staff that is appropriate to the bank s activities and its differing types of customers.

5 AML QUESTIONNAIRE 1 Country Assessment Yes No 1.1 Is Money Laundering a criminal offence? (Money Laundering is defined as the process by which the proceeds of crime are converted into assets including Bank or other deposits, so that they may be retained permanently or used to fund further crimes). 1.2 Are there specific laws and/or regulations in place covering Anti Money Laundering and Counter Terrorist Financing? 1.3 Are these laws and/or regulations in line with FATF Recommendations? 1.4 Does your country identified by FATF as a Cooperative Country? Do the laws and regulations in your jurisdiction permit: 1.5 The opening or maintenance of anonymous or numbered accounts? (ie the account owner s name is not readily available)? 1.6 Conducting business with Shell Banks (ie Banks with no physical presence in any jurisdiction)? 1.7 Conducting business with Politicians or Senior Public Officials? 1.8 Does the bank comply with the law and regulations in which jurisdiction operate? 2 AML Policy Yes No 2.1 Does your AML policy been approved by your Board of Directors or senior committee? 2.2 Is Implementation of Anti Money Laundering and Counter Terrorist Financing policies and procedures monitored on a permanent basis? Does your institution have an independent Review Function to ensure 2.3 correct implementation of AML policies? Internal & External Auditors 2.4 Does a particular area of your institution have specific responsibility for looking after AML and Compliance related issues?

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7 DESIGNATED OFFICIALS RESPONSIBLE FOR AML Money Laundering Reporting Officer (MLRO) Name Telephone # (+) Fax # (+) Website Mohamed A.Hameed A.Qader mohd.ahameed@alubafbank.com Deputy Money Laundering Reporting Officer (D. MLRO) Name Telephone # (+) Fax # (+) Website Najla Mahmood Hassan najla.mahmood@alubafbank.com

8 ANTI MONEY LAUNDERING STATEMENT ALUBAF Arab International Bank B.S.C Bahrain is licensed and regulated by the Central Bank of Bahrain (CBB), the bank comply with the Central Bank of Bahrain AML rules and regulations and all essential measures have been taken in combating Money Laundering and Financing Terrorism, in addition to complying with Financial Action Task Force 40 plus 9 recommendations on Anti-Money Laundering. ALUBAF Arab International Bank is governed by Central Bank of Bahrain which is committed to the FATF recommendations, International Anti Money Laundering regulations, sanctions, and Know Your Customers policies and procedures. These regulations have a legal framework supported by Bahrain anti money laundering law 2001 with respect to the Prevention and Prohibition of the Laundering of Money associated with its amendments issued in We hereby certify that the Bank policy and procedures are reviewed, approved and audited on an annual basis. All Bank staff are aware of these procedures, strictly adhered, and adequate compliance supervision processes are implemented. We are committed to adopt the international standards on Anti Money Laundering and Combating Financing Terrorism, in our endeavors to be compliant with these standards.

9 MAJOR SHAREHOLDERS LIST The shareholding structure of the Bank as at 31 st December 2012: Name of Shareholder Percentage Shareholding Nationality Libyan Foreign Bank 99.50% Libyan National Bank of Yemen 0.28% Yemeni Yemen Bank for Reconstruction & Development 0.22% Yemeni

10 BOARD OF DIRECTORS AND SENIOR MANAGEMENT Board of Directors Senior Management Moraja Gaith Solaiman Buhlaiga Chairman Suleiman Esa El Azzabi Director Ali Makhzum Ben Hamza Director Seyfullah Asaad Moosa Salim Director Fathi Ahmed Yahia Director Hasan K. Abulhasan Chief Executive Officer (CEO) Mohamed Saeed Ftera Senior Deputy CEO Mahmoud A. Azzouz Deputy CEO Saeed A.Nabi Hussain Al Banna Head of HR & Administrations A. Rahman Ahmed Khalfan Head of Business Development Ali Abdullah Head of Treasury & Investments Tallal El-Mshawat Head of IT Fatima Buali Head of Operations K.R. Usha Head of Financial Control Mohammed A.Hameed A.Razaq Head of Risk Management & Compliance Hassan A.Rahman Alsafar Head of Trade Finance Ismaeel Omer Ahmed Elnasri Head of Legal Abbas Abdulla Salim Al-Shamma Head of Audit