Terrorism Prevention (Reporting Entities) Regulations, 2010

THE TERRORISM PREVENTION ACT

THE TERRORISM PREVENTION (REPORTING ENTITIES) REGULATIONS, 2010

ARRANGEMENT OF REGULATIONS

Preliminary

1. Citation.
2. Interpretation. Guidance and Procedures to Prevent Relevant Terrorism Offences
3. Observance of guidance and due diligence.
4. Procedures and training to prevent relevant terrorism

offences.

5. Verification of customer identity and update of

customer information.

6. Transaction verification procedures.
7. Procedures re bodies corporate.
8. De minimis amounts not requiring identification.
9. Electronic funds transfers.
10. Payment by post, etc.
11. Identification procedures re transactions on behalf

of another.

12. Identification procedures, exemptions.
13. Identification procedures, supplementary provisions. Record-keeping and R~orting Procedures
14. Record-keeping procedures.
15. Internal reporting procedures.
16. Reporting entities not to operate anonymous accounts, etc.
17. Form of reports to designated authority. General
18. Application of standards to overseas branches and subsidiaries.
19. Directions from designated authority.
20. Exercise of functions by competent authority.
21. Requirements re existing customers. SCHEDULE

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THE TERRORISM PREVENTION ACT The Terrorism Prevention (Reporting Entities)

Regulations, 2010

In exercise of the power conferred upon the Minister by section 47 of the Terrorism Prevention Act, the following Regulations are hereby made:­ Preliminary Citation. 1. These Regulations may be cited as the Terrorism Prevention (Reporting Entities) Regulations, 2010. Interpre­ 2. In these Regulations ­ tation. "agent" means an applicant for business who acts other￾wise than as a principal; "applicant for business" means a person seeking to form a business relationship or carry out a one-off transaction with a reporting entitYi "business relationship" means any arrangement between two or more persons (at least one of them being a reporting entity) where the purpose of the arrange￾ment is to facilitate the carrying out of ­ (a) two or more transactions between themi or (b) transactions between them on a frequent, habitual or regular basis; "competent authority" has the meaning specified in section 18(5) of the Act; "customer information" includes the full name, current address, taxpayer registration number or other reference number and date and place of birth (in the case of an individual), of the applicant for business and, where applicable, the information

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Observance of guidance and due diligence. 2 referred to in regulation 13(1) (c); "designated authority" has the meaning specified in section 15(1) of the Act; "employee" means a person (including a person in a senior management position) who has entered into or works under a contract of services, or a contract for services, with a reporting entity, whether such contract is express or implied, oral or in writing; "one-off transaction" means any transaction carried out between two or more persons (whether or not the transaction is completed), other than a trans￾action carried out in the course of a business relationship; "relevant financial business" means any financial business carried on by a reporting entity; "relevant terrorism offence" means a terrorism offence under section 4, 5, 6, 7 or 8 of the Act; "reporting entity" means an entity falling within section 15(2) (a), (b) or (c) of the Act. Guidance and Procedures to Prevent

Re~evant Terrorism Offences

3. • (1) In determining whether a person has complied with any of the requirements of these Regulations, a court shall take acc~unt of any relevant guidance that was at the time concerned issued by the designated authority, competent authority or a body that regulates, or is representative of, any trade profession, business or employment concerned ­ (a) with the approval of the Minister; and (b) published in the Gazette. (2) In proceedings against any person for an offence under these Regulations, it shall be a defence for that

3 Procedures and training to prevent relevant terrorism offences. person to show that he took all reasonable steps and exercised due diligence to avoid committing the offence. 4. - (1) No reporting entity shall form a business relationship, or carry out a one-off transaction, with or for another person, unless the reporting entity ­ (a) maintains the following procedures in relation to that business relationship or one-off transaction ­ (i) identification procedures and transaction verification procedures in accordance with regulations 5 to 11 and 13; (ii) record-keeping procedures in accordance with regulation 14; (iii) internal reporting procedures in accor￾dance with regulation 15; (b) takes appropriate measures, from time to time, for the purpose of making its employees, whose duties include the handling of relevant financial business, aware of ­ (i) the procedures under sub-paragraph (a) which relate to the relevant financial business in question; and (ii) the provisions of the Act and any regulations made thereunder; and (c) provides such employees, from time to time, with

training in the recognition and handling of

transactions ­ (i) carried out by, or on behalf of a listed entity; or (ii) which constitute, or appear to constitute, transactions involving funds that may be related to the

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commission of a relevant terrorism offence. (2) A person who fails to comply with paragraph (l) commits an offence and is liable upon conviction before a Resident Magistrate's Court to - (a) in the case of an individual, a fine not exceeding one million dollars or imprisonment for a term not exceeding twelve months, or both such fine and imprisonment; and (b) in the case of a body corporate, a fine not exceeding three million dollars. Verification of customer identity and update of customer information. 5. Subject to regulation 8, identification procedures maintained by a reporting entity under regulation 4{1) (a) are in accordance with this regulation if such procedures require that - (a) as soon as is practicable after contact is first made between the reporting entity and an applicant for business concerning any particular business relationship or one-off transaction - (i) the applicant for business produces to the reporting entity satisfactory evidence of the applicant's identity; (ii) the reporting entity takes such measures (as are specified in its identification procedures) as will verify the appli￾cant's identity; and (iii) where the reporting entity is unable to verify the applicant's identity, the business relationship or one-off trans￾action in question shall not proceed any further; and (b) as regards every business relationship, the

5 reporting entity concerned shall update all customer information ­ (if at least once in every five years during the course of the business relationship; (ii) whenever there is any doubt about the veracity or adequacy of previously obtained customer information; and (iii) where customer information is not updated as required under this sub-paragraph, the business relationship in question shall not proceed any further. Transaction 6. - (1) Transaction verification procedures maintained verification procedures. by a reporting entity under regulation 4(1) (a) are in accordance with this regulation if such procedures require that ­ (a) as concerns any business relationship or one-off transaction, the reporting entity takes such measures (as specified in its transaction verification procedures) as will produce satisfactory evidence as to the purpose and intended nature of the business relationship or one-off' transaction in any of the circumstances specified in paragraph (2); and (b) where such evidence is not obtained, the business relationship or one-off transaction in question shall not proceed any further. (2) The circumstances referred to in paragraph (1) are as follows ­ (a) where any transaction involves such amount as may be prescribed; (b) where transactions carried out in a single

Procedures re bodies corporate. De minimis amounts not requiring identifi￾cation. Electronic funds transfers. 6 operation or in several operations appear to be linked; (c) where a transaction is carried out by means of any wire transfer; (d) where there is any doubt about the veracity or adequacy of previously obtained evidence of identity; (e) where the reporting entity is required to make a report under section 16(3) of the Act. 7. For the purposes of regulations 5 and 6, where the

applicant for business is a body corporate ­ (a) the reporting entity shall carry out reasonable due diligence procedures (including the procedures mentioned in regulation 13(1) (c) (ii)) concerning the identification of the body corporate and transaction verification; and (b) evidence that such procedures have been carried out shall be sufficient. 8. - (1) The identification procedures set out in regulation 5 shall not be required of a reporting entity in the case of transactions of a value of two hundred and fifty dollars or less in the currency of the United States of America or its equivalent in any other currency, unless the employee handling the transaction knows or suspects that the transaction constitutes a transaction involving funds that may be related to the commission of a relevant terrorism offence. (2) The provisions of paragraph (1) do not apply to an approved money remittance or money transfer agency or agent, as defined by section 2 of the Bank of Jamaica Act. 9. - (1) A reporting entity conducting wire transfers or any other electronic funds transfer shall ensure that it

Payment by post, etc. 7 receives and includes in its records, accurate and relevant information on funds transfers throughout the payment process and chain, including the correct name, address and account number (if any) of the persons involved, any other relevant reference numbers, and the instructions given in relation to the transfer. (2) For the purposes of paragraph (1), "persons involved" means ­ {a} the holder of the account that is the source from which the funds are transferred; (b) the person that places the order for the transfer of the funds; and (c) every recipient of the funds transferred. {3} A person who fails to comply with paragraph (1) commits an offence and is liable on conviction before a Resident Magistrate's Court to ­ (a) in the 'case of an individual, a fine not exceeding one million dollars or imprisonment for a term not exceeding twelve months, or both such fine and imprisonment; (b) in the 'case of a body corporate, a fine not exceeding three million dollars. 10. - (1) Paragraph (2) shall apply in any case where ­ {a} a payment is to be made by an applicant for business; (b) it is reasonable in all the circumstances for the payment to be made, or the details thereof to be sent, by post or by telephone or any other electronic means; and (c) satisfactory evidence of the identity of the applicant for business would, but for this regulation, be required under identification pro­

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Identifi￾cation procedures re trans￾actions on behalf of another. cedures adopted in accordance with regulation 5. (2) The fact that a payment is ­ (a) debited from an account held in the applicant's name at any of the financial institutions specified in paragraph (4) (whether the account is held by the applicant alone or jointly with one or more other persons); or (b) made on behalf of the applicant from an account held by or with ­ (i) an insurance company registered under the Insurance Act; or (ii) a person licensed under the Securities Act as a dealer or investment adviser, shall constitute the required evidence of his identity for the purpose of regulation 5. (3) For the purposes of paragraph (1), it is immaterial whether the payment or its details are sent or given to a reporting entity or to some other person acting on the reporting entity's behalf. (4) The financial institutions referred to in paragraph (2) (a) are ­ (a) a bank licensed under the Banking Act; (b) a financial institution licensed under the

Financial Institutions Act;

(c) a building society licensed under the Building Societies Act; (d) a society registered under the Co-operative

Societies Act.

11. (1) This regulation applies where, in relation to any business relationship or transaction, a person is, or appears to be, an agent. (2) Identification procedures maintained by a

9 reporting entity under regulation 4(1) (a) are in accordance with this regulation if, in every case to which this regulation applies, the reporting entity requires reasonable measures to be taken for the purpose of ­ (a) establishing the identity of the principal and the agent; and (b) verifying that the agent is authorised to act on behalf of the principal. (3) In determining for the purposes of paragraph (2), what constitutes reasonable measures in any particular case, regard shall be had to all the circumstances of the case and, in particular, to the best practice which, for the time being, is followed in the relevant field of business and is'applicable to those circumstances. (4) Without prejudice to the generality of paragraph (3), if the conditions specified in paragraph (5) are fulfilled in re ion to an agent (whether the principal is undisclosed or disclosed for reference purposes only) it shall be reasonable for a reporting entity to accept a written assurance from the agent to the effect that evidence of the identity of any principal on whose behalf the agent may act in relation to the reporting entity has been obtained and recorded under procedures maintained by the agent. (5) The conditions referred to in paragraph (4) are that, in relation to the business relationship or transaction in question, there are reasonable grounds for believing that ­ (a) the agent is based or incorporated in, or is formed under the law of, a country in which there are in force in relation to the agent provisions

10 at least equivalent to those mentioned in sections 4, 5, 6, 7, 8, 15 and 16 of the Act and regulations 4, 5, 6, 7, 9, 13, 14, IS, 16, 18 and 21; and (b) the agent ­ (i) is a person to whom regulation 4(1) would apply if the agent were situated in Jamaica; and (ii) acts in the course of a business in relation to which a foreign regulatory authority exercises regulatory functions and control in respect of the provisions referred to in sub-paragraph (a). Identifi­ 12. - (1) Subject to paragraph (3), where ­ cation procedures, (a) there are reasonable grounds for believing that an exemptions. applicant for business is a reporting entity; or (b) anyone-off transaction is carried out with or for a third party pursuant to an introduction effected by a person who identifies the third party and has provided an assurance in accordance with paragraph (2), regulations 5 and 11 shall be construed as entitling the reporting entity to exercise its discretion as to whether or not to require any steps to be taken to obtain evidence of the identity of the applicant for business. (2) The assurance referred to in paragraph (I) is that evidence 9f the identity of all third parties introduced by the person mentioned in paragraph (I) (b) will have been obtained and recorded under procedures maintained by him and ­ (a) that person falls within paragraph (I) (a) i or (b) there are reasonable grounds for believing that

11 the conditions mentioned in regulation 11(5) (a) and (b) are fulfilled in relation to that person. (3) Nothing in this regulation shall apply in circumstances where any person handling the transaction knows or suspects that the transaction amounts to the commission of a terrorism offence. Identifi￾cation procedures, supple￾mentary provisions. 13. - (1) For the purposes of these Regulations, evidence of identity is ,satisfactory if - (a) it is reasonably capable of establishing that the applicant for business is the person the applicant claims to be; (b) the person who obtains the evidence is reasonably satisfied, in accordance with the procedures maintained under these Regulations in relation to the reporting entity concerned, that such evidence establishes the fact that the applicant for business is the person the applicant claims to be; (c) in the case of any transaction involving - (i) a settlement, trust or other type of legal arrangement, it establishes the identity of the settlor, legal owner or other person who exercises effective control of the legal arrangement, as the case may require, and the beneficial owner; (ii) a person other than an individual, it establishes - (A) the identity of the individuals who exercise ultimate effective control over that person; and (B) in the case of a body corporate, it includes

12 evidence of incorporation and establishes the identity of each director and shareholder (if any). (2) In determining for the purposes of regulation 5 the period within which satisfactory evidence of the identity of the applicant for business has to be obtained, in relation to any particular business relationship or one-off transa~tion, all the circumstances shall be taken into account, including ­ (a) the nature of the business relationship or the one-off transaction concerned; (b) the geographical locations of the parties; and (c) whether it is practical to obtain the evidence before commitments are entered into between the parties or before any money is transferred. {3} For the purposes of paragraph {I} (c) (ii) {A}, a person shall be regarded as exercising ultimate effective control over the entity concerned if ­ (a) the person is in a position to determine the policy of the entity or to make the final determination as to decisions to be made by the entity; or (b) the person by himself or together with a connected person would be in a position to control fifty-one percent or more of the voting power in the entity or would hold interest in fifty-one percent or more of the issued shares of the entity. (4) For. the purposes of paragraph (2), the following persons shall be treated as being connected with a given entity "A" and the entity with them, and shall be so treated notwithstanding that at the relevant time any

13 of the persons in question (not being individuals) had not yet come into existence or had ceased to exist ­ (a) a holding company or subsidiary of Ai (b) a subsidiary or holding company of A; (c) a holding company of a subsidiary of A; (d) any company of which A has control; (e) any company of which A and persons connected with A together have control; (f) any company which together with A constitute a group; (g) an individual who is a director, manager or a person who has control of A or any partner or any immediate relative of such director, manager or person aforesaid; (h) any company of which any of the persons referred to in sub-paragraph (g) is a director, manager or has control. (5) For the purposes of subsection (4) (f), "group" in relation to a company means that company and ­ (a) any other company which is its holding company or subsidi'ary; (b) any other company which is a subsidiary of the holding companYi (c) any company which directly or indirectly controls or is c'ontrolled by any company referred to in sub-paragraph (a) or (b) i (d) any company which is controlled by a person who directly or indirectly controls a company referred to in sub-paragraph (a), (b) or (c). (6) For the purposes of this regulation, a company is the holding company of any company that is its immediate, intermediate or ultimate subsidiary, whether

Record￾keeping procedures. Internal reporting 14 the holding company holds that other company's shares on trust or is the beneficial owner of such shares. Record-keeping and Reporting Procedures 14. - (1) Record-keeping procedures maintained by a reporting entity under regulation 4(1) (a) are in accor￾dance with this regulation if they require the keeping of a record for the prescribed period in accordance with paragraphs (2), (3) and (4). (2) Where evidence of the identity of an applicant for business is obtained under procedures maintained in accordance with regulation 5, 6, 7 or 11 a record shall be kept in accordance with paragraph (3). (3) The record referred to in paragraph (2) shall indicate the nature of the evidence and shall ­ (a) comprise a copy of the evidence; (b) provide such information as would enable a copy of it to be obtained; or (c) in a case where it is not reasonably practicable to comply with sub-paragraph (a) or (b), provide sufficient information to enable the details as to a person's identity contained in the relevant evidence to be re-obtained. (4) In relation to all relevant financial business, a record shall be kept of each transaction, in such manner and form as shall facilitate the reconstruction of trans￾actions. (5) For the purposes of this regulation, the prescribed period is a period of five years commencing with the date on which the relevant financial business was completed or the business relationship was terminated, whichever occurs later. 15. Internal reporting procedures maintained by a

15 procedures. reporting entity shall include provisions ­ (a) for identifying a person in accordance with section 18(3) of the Act (in this regulation referred to as "the nominated officer") to whom a report is to be made of any information or other matter which ­ (i) comes to the attention of a person handling relevant financial businessi and (ii) in the opinion of the person handling that business ­ (A) requires that a determination be made under section 15(2) of the Act that the reporting entity is in possession or control of property owned or controlled by or on behalf of a listed entitYi (B) is a complex, unusual or large transaction or an unusual pattern of transactions, having no apparent economic or obviously lawful purpose or gives rises to a suspicion that the transaction (whether completed or not) involves funds that may be related to the commission of a relevant terrorism offencei or (C) the circumstances require that the details of the transaction and its surrounding circum­

16 stances be recorded and that the recording be maintained in such manner as to enable scrutiny by the designated authority or competent authority (as the case requires) ; (b) requiring that any such report be considered, in the light of all other relevant information, by the nominated officer or by another person acting on behalf of the nominated officer, for the purpose of determining whether or not the infor￾mation or other matter contained in the report gives rise to a duty to make a report under section 15(3} or 16(3} of the Act; (c) for any person charged with considering a report in accordance with sub-paragraph (b) to have reasonable access to other information that may be of assistance to him and is available to the reporting entity; and (d) for any person charged with considering a report in accordance with sub-paragraph (b) to make such reports to the designated authority as may be required under sections 15(3) and 16(3) of the Act. Reporting 16. - (I) A reporting entity shall not, in the course of entities not to its relevant financial business, permit any person to operate anonymous conduct any transaction with the reporting entity by means accounts, etc. of a numbered account, an anonymous account or any account in a fictitious name. (2) In this regulation ­ "anonymous account" means any account for which the

17 reporting entity does not have such information as would, when subjected to the identification and transaction verification procedures required by these Regulations, constitute evidence of identity which meets the requirements of regulations 11 and 13; "fictitious name" means any name which, when subjected to the identification procedures required by these Regulations, does not constitute, in relation to the person conducting the transaction, such evidence of identity as meets the requirements of regulations 11 and 13; "numbered account" means an account that is identifiable solely by reference to the numeral assigned to that account. Form of reports to designated authority. 17. - (1) Subject to paragraph (4), a report to the designated authority made pursuant to section 15 of the Act (listed entity reporting) shall be in the form set out Schedule. Form 1 as Form 1 (2) of the Schedule. Subject to paragraph (4) a report made pursuant to section 16 of the Act (suspicious transactions Form 2 Schedule. reporting) Schedule. shall be in the form set out as Form 2 of the (3) A report made under paragraph (1) or (2) may - (a) contain such adjustments to the applicable form set out in the Schedule; and (b) be submitted in such electronic form, as may be approved by the designated authority. (4) A report from a reporting entity in respect of relevant financial business conducted outside of Jamaica, submitted pursuant to paragraph (1) or (2), may be in such form as may be approved by the designated authority.

18 Application of standards to overseas branches and subsidiaries. (5) Upon receiving a report submitted pursuant to paragraph (1) or (2}1 the designated authority shall issue to the reporting entity a receipt therefor. (6) No receipt issued under paragraph (5) shall be construed as signifying compliance with these Regulations as regards the contents of any report. Genera~ 18. - (1) Subject to paragraph (2) I every reporting entity shall ensure that its branches and subsidiaries situated outside of Jamaica implement and conform with the provisions of the Act and any regulations thereunder. (2) Whenever there is a difference in applicable standards between the jurisdiction where the reporting entity is located and the jurisdiction where any of its branches or subsidiaries is locatedI the reporting entity shall comply with the higher required standard. {3} Where any reporting entity becomes aware of any instance in which any of its branches or subsidiaries situated outside of Jamaica is unable to conform to the standards and conduct set out in sections 15 to 18 of the Act or in these Regulations I the reporting entity shall ensure that in each such instance ­ (a) the branch or subsidiary advises it of the reason for the inabilitYi and (b) the reporting entity advises the competent

authority of the inability and the reason

therefor.

(4) A p'erson who contravenes paragraph (1) or (3) commits an offence and is liable upon conviction before a Resident Magistrate/s Court to ­ (a) in the case of an individual a fine not exceeding one million dollars or to imprisonment for a term

19 not exceeding twelve months or both such fine and imprisonment; or (b) in the case of a body corporate, a fine not exceeding three million dollars. Directions 19. - (1) In making a report under section 16 of the Act, from designated a reporting entity shall comply with such directions as authority. may be given by the designated authority. (2) The directions which may be given pursuant to paragraph (1) or under section 15(4) of the Act (report as to possession or control of property owned or controlled by or on behalf of a listed entity) may include directions in relation to - (a) previous or current reports; (b) the provision of information required in such reports; and (c) the provision of additional information in relation to queries concerning specific matters arising from the report, including - (i) due diligence procedures followed in relation to a specific transaction; (ii) persons authorized to sign on the account in question; (iii) errors identified in the reports; and (iv) such other matters as may be specified in the directions. (3) A reporting entity that fails to comply with paragraph (1) commits an offence and is liable upon conviction before a Resident Magistrate's Court to - (a) in the case of an individual, a fine not exceeding one million dollars or imprisonment for a term not exceeding twelve months or both such fine and imprisonment;

Exercise of functions by competent authority. Requirements re existing customers. 20

(b) in the case of a body corporate, a fine not exceeding three million dollars. 20. For the purposes of the Act, the competent

authority ­ (a) shall exercise its functions with a view to monitoring compliance by reporting entities with the requirements of the Act and any regulations made under the Act; and (b) may issue guidelines to reporting entities regarding effective measures to prevent the commission of relevant terrorism offences. 21. - (1) Except as otherwise provided in this regulation, th~ obligations of a reporting entity under these Regulations shall apply, in respect of any business relationship formed by the reporting entity prior to the relevant date, as they apply in respect of an applicant for business. (2) Subject to paragraph (3), nothing in these Regulations shall require a reporting entity to maintain procedures in accordance with regulations 5 and 11 which require evidence to be obtained in respect of any business relationship formed by the reporting entity prior to the relevant date, as to the identity of the person with whom that relationship has been formed. (3) Notwithstanding paragraph (2), the provisions of regulation 5(2) shall, as of the relevant date, apply to the updating of evidence of identity in relation to any business relationship formed by the reporting entity prior to the relevant date. (4) In this regulation, "relevant date" means the date of coming into operation of these Regulations.

21 SCHEDULE Form 1 (Regulation 17(1» THE TERRORISM PREVENTION ACT The Terrorism Prevention (Reporting Entities)

Regu1ations, 2010

Report under section 15 - Possession or Control

of Property Owned or Controlled by or on

Behalf of a Listed Entity

EXCEPT AS PROVIDED IN SECTION 15 OF THE ACT, IT IS AN OFFENCE TO

DISCLOSE THE EXISTENCE OF THIS REPORT TO ANYONE (INCLUDING THE

CUSTOMER)

TO: [Insert name and address of the designated authority] PART A - GENERAL INFORMATION Report: Number: !lYPe of report:: o Initial report, dd/mm/yyyy o Report for period of four calendar months from dd/mm/yyyy

to dd/mm/yyyy

o Report in response to request made by designated authority on dd/mm/yyyy o Special report Reporting Entity: Name of reporting entity: Postal address of reporting entity: Address for service of documents: Telephone No. (s) : Facsimile No. (s) : E-mail address: Name of Chief Executive Officer: Name of person making report (Declarant): Telephone No. (s) :

\ \ .. 22

Type of Entity: D Foreign company engaged in the business D Banking D Securities o Insurance o Investment advice o Trust Other o Financial institution: o Bank o censee (financial institution) D Building society D Co-operative society o Licensed operator of exchange bureau o Money transfer and remittance agents o Other [J Insurance company o Dealer (securities) o Investment adviser (securities) D Entity designated by Minister D Other PART B DETERMINATION: In respect of the abovementioned reporting period it is determined that (reporting entity) . ­ o IS NOT in possession or control of property owned or controlled by or on behalf of a listed entity. o IS in possession or control of property owned or controlled by or on behalf of a listed entity, the particulars of which are set out in Part C. REASON FOR DETERMINATION: PART C Particulars re Property Owned or Controlled by or on Behalf of Listed Entity [NB: Complete separate sheets in respect of each listed entity] .

1. PARTICULARS OF LISTED ENTITY: If individual(s) ­ Person's full nam~(s): Gender: Date(s) of birth:

..

23 Place{s) of birth: Passport or ID number{s) : Nationality{ies) : Address (es) : Telephone No. Home: Work: Mobile: Occupation/employer: (If group, trust, partnership or fund or an unincorporated association or organization, NAME AND ADDRESS AND REGISTRATION NUMBER) : 2 . PROPERTY INFORMATION (complete in respect of each property) Oescription of the property: Registration or identification number or other identification information: Value: particulars* of registered owner (if applicable) : 3. LISTED ENTITY INFORMATION Particulars* of listed entity: Reasons for determining that the property is owned or controlled by the listed entity: 4 • ACCOUNT INFORMATION (Complete where the property involves an account) Account number: Branch: Type of Account:

---

24 Date opened: Date opened: Status: D Active D Inactive D Closed Date closed (if applicable) : 5. TRANSACTION INFORMATION (Complete in respect of each transaction involving the property) Date of transaction{s) Date of posting{s) : Description of transaction{s) Particulars* of person conducting the transaction: Particulars* of principal, if person conducting the transaction is acting as agent: Particulars* of other institutions, persons and accounts involved: [*Particulars include name, address, contact number, identification number and any other relevant customer information] Name of Signature: _____________________ compliance office Date: __________________ Telephone number: _____________________ PART D - DECLARATION I/We A.B., solemnly and sincerely declare that, to the best of my knowledge and belief, and after making reasonable enquiries, the information contained in this report is accurate and I/we make this solemn declaration conscientiously believing the same to be true, and by virtue of the Voluntary Declarations Act. Taken and acknowledged this day of 20 , before me C.D. A.B Justice of the Peace for the parish of

25 Form 2 (Regulation 17(2)) THE TERRORISM PREVENTION ACT The Terrorism Prevention (Reporting Entities) Regulations, 2010 Suspicious Transactions Report (under section 16) I PARTt IReporting Entity Information L Name of Reporting Entity: 2. Address of Reporting Entity: 3. T.R.N.: 4. Branch address: 5. Type of Reporting Entity: PART 2 Person(s) involved in transaction(s): Section A Persons on whose behalf transaction is conducted (Customer): /6. Multiple persons [ 7. Individual's last name or organization's name: 8. First name: 9. M.1. 10. Permanent Address: II. Date of Birth (DDIMMfYY): 12. T.R.N.: 13. Method used to verity identity: [ ] Examined identification credential/document [ ] Known Customer - Information on file 14. Describe identification credential: a. [ ] Driver's licence b. [ ] Passport c. [ ] Nationall.D. d. [ ] Other, specify e. issued by: f. Number: 15. Customer's Account No. and Type: J6. OccupationlBusiness/Principal Activity: Section B Person(s) conducting transaction (Agent) 117. Multiple persons [ ] See Part 6 ] J8. Individual's last name or organization's name: 119 . First Name: 20. M.I. 21. Permanent Address: 22. Date of Birth (DDlMMfYY): 23. T.R.N. : 24. Method used to verity identity a [ ] Examined Identification credential/document b [ ] Known Customer-Information on file 25. Describe identification credential: a. [ ] Driver's licence b. [ ] Passport c. [ ] National I. D. d. [ ] Other specify e. Issued by: f. Number Section C Person(s) benefiting from transaction 26. Multiple persons [ ] See Part 6 27. Individual's last name or organization's name: 28. First Name: 29. M.1. 30. Permanent Address: PART 3 I Preparer Information 31. Last Name: 32. First Name: 33. M.L i 34. Title: 35. Phone No.: 36. Signature: 37. Date of Signature (DD/MMNYYY): PART 4 IContact for Assistance (If different than preparer info. in Part 3 38. Last Name: 39. First Name: 40. M.L i I i I i i

~ , . "'­ 26 41. Title: 142. Phone No.: I PARTS ITransaction Details: 1. Multiple Transaction ( ) 2. Transaction Type: 3. Date (DDIMMlYYYY): 14. Title: 5. Transaction Currency: [6. Transaction Account: 7. Accounts Affected (if any): 8. JA$ Equivalent: 9. JA$ Exchange Rate: Type Number 10. US$ Equivalent: I I. US$ Exchange Rate: 12. Source of funds: 13. Transaction Type: 14. Date (DDIMMNYYY): 115. Time: 16. Transaction Currency: 17. Transaction Amount: 18. Accounts Affected (if any): 19. JA$ Equivalent: 20. JA$ Exchange Rate: Type Number 21. US$ Equivalent: 22. US$ Exchange Rate: 23. Source of funds: 24. Transaction Type: 25. Date (DDIMMlYYYY): 26. Time: 27. Transaction Currency: I 28. Transaction Account: 29. Account Affected: 30. JA$ Equivalent: 31. JA$ Exchange Rate: Type Number 32. US$ Equivalent: 33. US$ Exchange Rate: 34. Source offunds: 35. Transaction Type: 36. Date (DDIMMNYYY): 137. Time: 38. Transaction Currency: 39. Transaction Account: 40. Account Affected: 41. JA$ Equivalent: 42. JA$ Exchange Rate: Type Number 43. US$ Equivalent: 44. US$ Exchange Rate: 45. Source of funds: PART 6 I Reason for opinion that transaction falls within section 16(3)

• I L .. 27 ~.------------------------------------------~------------------------------ ! f--.---------------------------------------.-------------------------­ Dated this day of , 2010. Minister of Foreign Affairs and Foreign Trade

... ( .. THE TERRORISM PREVENTION ACT THE TERRORISM PREVENTION (REpORTING ENTITIES) REGULATIONS, 2010 ARRANGEMENT OF REGULATIONS Prelimina.r:y ............ ".................. .....-------­ 3. Observance of guidance and due diligence. 4. Procedures and training to prevent relevant terrorism

offences.

5. Verification of customer identity and update of

customer information.

6. Transaction verification procedures.
7. Procedures re bodies corporate.
8. De minimis amounts not requiring identification.
9. Electronic funds transfers.
10. Payment by post, etc.
11. Identification procedures re transactions on behalf

of another.

12. Identification procedures, exemptions.
13. Identification procedures, supplementary provisions. Record-keeping and Reporting Procedures
14. Record-keeping procedures.
15. Internal reporting procedures.
16. Reporting entities not to operate anonymous accounts, etc.
17. Form of reports to designated authority. General
18. Application of standards to overseas branches and subsidiaries.
19. Directions from designated authority.
20. Exercise of functions by competent authority.
21. Requirements re existing customers. SCHEDULE