Version as of Apr. 2 5, 201 1 Anti-Money Laundering

1. private intelligence & risk management company Version as of Apr. 25, 2011 Anti-Money Laundering Specific Character of Russia and CIS countries CEO & Founder Private intelligence company “R-Techno” Roman V. Romachev 47, Volgogradskiy pr., Moscow, 109316 Tel./fax: +7 (495) 723-01-19 e-mail: r-techno@it2b.ru, www.r-techno.com

2. private intelligence & risk management company • Specific Character of Russia and CIS countries • Between 1991 and 2009 in Russia, “money laundering” schemes were far less popular than the so-called “conversion into cash”. Some banking experts connect to the fact that the origin of capitals obtained illegally during that period of time captured interest neither of the government nor of the citizens, and correspondingly no one required legitimization (laundering) of the capitals. This is what former banker Aleksey Frenkel said about it: • Let’s start with terms. 5 years have just passed since the approval of the Federal Law No. 115-FZOn Counteraction of Legitimization (Laundering) of the Proceeds of Crime and Financing of Terrorism. The banking sphere calls this statutory act shortly – “Law 115”. And so will we. Let’s ponder over the meaning of the following phrase – “legitimization (laundering) of the proceeds of crime”. A drug kingpin got an amount of money obviously from illicit sources, i.e. by selling drugs. He wants to buy something useful for this money, such as a house, a yacht, a car or jewellery. In the West, to make his dream come true he will have to legitimize the proceeds of crime, to turn it from “the black money” into “the white money”. Otherwise, there will be no purchase. In order to prevent that, all the Western countries passed laws similar to our Law 115 and formed an international organization – FATF, which should coordinate efforts and exchange information between the countries, fighting against the money laundering. Seriously, if a drug kingpin can’t use his money to buy material benefits, why on Earth did he earn it? Wouldn’t it be better to do some farming and switch over from cultivation of opium poppy to breeding calves? • Now let’s look at what is going on in Russia.Unlike the West, one may buy absolutely anything in Russia for “the black money”, such as a house, a yacht, a car and jewellery. No one is actually surprised about it in our country. Consequently, in Russia people, who earned money illegally, have no incentives to legitimize (or launder) money unlike in the West. No one wants to launder money, i.e. to turn it from “the black (dirty) money” into “the white (clean) money” in Russia. Based on the viewpoint, which is so much common in our country, that the fortunes earned on privatizationwere made illegally, we will additionally have to say that one may buy even plants, newspapers, steam vessels and even entire sectors of the national economy for the proceeds of crime. • — Letter of Aleksey Frenkel Article, Kommersant 47, Volgogradskiy pr., Moscow, 109316 Tel./fax: +7 (495) 723-01-19 e-mail: r-techno@it2b.ru, www.r-techno.com

3. private intelligence & risk management company Specific Character of Russia and CIS countries Thus, the AML system in Russia and CIS should include counteraction of the illegal conversion of money into cash (“cash-out”). AML-risks One of the most serious bank risks related to the lack of proper attention to the anti-money laundering procedure is Illegal conversion of money into cash also leads to LICENSE REVOCATION 47, Volgogradskiy pr., Moscow, 109316 Tel./fax: +7 (495) 723-01-19 e-mail: r-techno@it2b.ru, www.r-techno.com

4. private intelligence & risk management company Know Your Customer This is a general principle for all the banks that any efficient anti-money laundering is based on the know your customer (KYC) concept. • AML outsourcing from R-Techno • General set of measures to study the customer: • Check of the reliability of the information provided on the company; • Confirmation of the company’s location; • Check in the international and Russian ban-, stop listsand black lists; • Check of the founders and executives for mass participation in other companies; • Check for the implication of the company and top managers in financing of the terrorist organizations and organized crime; • Check for the implication of the company and top managers in laundering of the proceeds of crime and any illegal activities; • Check of the customer’s court history; • Open-Source Intelligence (OSINT) – Internet, mass media, etc. • R-Techno performs checks across more than 27,000 documents of departmental structures both Russian and international! This is a unique archive of R-Techno, which is expanded on a daily basis, ensuring the customer gets the up-to-date information! 47, Volgogradskiy pr., Moscow, 109316 Tel./fax: +7 (495) 723-01-19 e-mail: r-techno@it2b.ru, www.r-techno.com

5. private intelligence & risk management company Model report 47, Volgogradskiy pr., Moscow, 109316 Tel./fax: +7 (495) 723-01-19 e-mail: r-techno@it2b.ru, www.r-techno.com

6. private intelligence & risk management company Counteragent AML-check costs One-time check – 40 euros Subscriber check (subscription – 1 000euros per month) – 30 checks per month) Subscriber check (subscription – as from2 000euros per month) – 65checks per month) 47, Volgogradskiy pr., Moscow, 109316 Tel./fax: +7 (495) 723-01-19 e-mail: r-techno@it2b.ru, www.r-techno.com

7. private intelligence & risk management company Contacts Roman V. Romachev www.r-techno.com +7 495 723.01.19 47, Volgogradskiy pr., Moscow, 109316 Tel./fax: +7 (495) 723-01-19 e-mail: r-techno@it2b.ru, www.r-techno.com