Instruction No. 2000-09 of October 18, 2000, on information regarding the anti-money laundering and counter-terrorist financing prevention system (consolidated version)

Prudential Control Authority 1 Instruction No. 2000-09 of October 18, 2000 amended by Instructions No. 2001-03 of November 20, 2001, No. 2002-03 of March 28, 2002, No. 2003-04 of November 4, 2003, No. 2006-05 of November 23, 2006, No. 2009-01, No. 2009-02 of June 19, 2009, No. 2009-07 of November 30, 2009, No. 2010-07 of March 8, 2010 and No. 2011-I-15 of November 7, 2011 regarding information on the system for preventing money laundering and the financing of terrorist activities

Article 1 The following are hereinafter referred to as "subject entities": the persons mentioned in paragraph 1 a) of I of Article L 561-36, with the exception of the persons mentioned in Articles L. 524-2 and L. 613-1-1 of the Monetary and Financial Code.

Subject entities must submit the BLANCHIMT tables in the annex to this instruction: – B1 - Identity of declarants and Tracfin correspondents; – B2 - Branches in countries where local provisions oppose the implementation of the obligations mentioned in Articles L. 561-34 and R. 561-29 of the Monetary and Financial Code; – B3 - Subsidiaries in countries where local provisions oppose the implementation of the obligations mentioned in Articles L. 561-34 and R. 561-29 of the Monetary and Financial Code; – B4 - Internal procedures; – B5 - Data concerning the last closed fiscal year; – B6 - Status of branches established in the States or territories mentioned in VI of Article L. 561-15 of the Monetary and Financial Code; – B7 - Status of subsidiaries established in the States or territories mentioned in VI of Article L. 561-15 of the Monetary and Financial Code.

Article 2 The information provided on the tables mentioned in Article 1 is finalized on December 31 of each calendar year.

Article 3 The tables are prepared under the responsibility of the persons mentioned in the second paragraph of Article L. 511-13, in paragraph 4 of Article L. 532-2, or in Article L. 518-11 of the Monetary and Financial Code.

They are sent no later than February 28 of each year to the General Secretariat of the Banking Commission by electronic transmission and electronically signed according to the procedures defined by Instruction No. 2007-01.

However, by exception to the second paragraph of Article 3 of Instruction No. 2007-01, only the executives of the subject entities as defined in the second paragraph of Article L. 511-13, paragraph 4 of Article L. 532-2, or Article L. 518-11 of the Monetary and Financial Code are authorized to sign. For the cases provided for in the third paragraph of Article 3 of Instruction No. 2007-01, only the executives of the delegated entity are authorized to sign. For the cases provided for in the fourth paragraph of Article 3 of Instruction No. 2007-01, only the executives of the central body as defined in Articles L. 511-30 and L. 511-31 of the Monetary and Financial Code are authorized to sign.

Instruction No. 2000-09 of October 18, 2000 (consolidated version as of 07/11/2011) Prudential Control Authority 2

Furthermore, in the event of the designation of one or more declarants or Tracfin correspondents during the year, the updated data regarding the identity of the declarants and Tracfin correspondents included in table B1 mentioned in Article 1 are sent to the General Secretariat of the Banking Commission using the same transmission methods.

Article 4 Subject entities must keep the collected information and all documents used to prepare them available to the Banking Commission for a period of five years from the date of transmission.

Article 5 "By exception to Articles 1 and 3, second paragraph, branches of investment firms having their registered office in another Member State of the European Union or party to the Agreement on the European Economic Area must submit to the General Secretariat of the Banking Commission, no later than April 30 of each year, only tables B1, B4, and B5, as well as the report on the conditions under which internal control is ensured in the fight against money laundering and terrorist financing, established in application of Articles 42 and 45 of Regulation No. 97-02.

They must also submit by the same date a description of the branch's activity, including: – an annual balance sheet and income statement of the branch; – full-time equivalent staff, defined as persons actually working for the branch, whether or not they belong to its staff, counted on a pro-rata basis for part-time work during the year in question; – a description of the branch's organization, including an organizational chart, mentioning the different units, their affiliation, their role, and their staff numbers; – the mention of investment services actually exercised during the year in question; – activity indicators for the year in question, namely the number of clients and their distribution by categories, as well as the number and volume of operations, with a breakdown by type of operations. The branch selects the relevant client categories and types of operations with regard to its activity and the risks of money laundering or terrorist financing.

These information are finalized on December 31 of each calendar year."

Instruction No. 2000-09 of October 18, 2000 (consolidated version as of 07/11/2011) Prudential Control Authority 3

Annex No. Line Quality (a) Name First Name Function Date of Designation Telephone Number Fax Number Email Address 1 2 3 4 5 6 7 8 9 (a) Mr., Mrs., Miss No. Line Quality (a) Name First Name Function Date of Designation Telephone Number Fax Number Email Address 1 2 3 4 5 6 7 8 9 (a) Mr., Mrs., Miss B1 - Identities of Tracfin Declarants B1 - Identities of Tracfin Correspondents BLANCHIMT Information relating to the system for preventing money laundering and the financing of terrorist activities

Instruction No. 2000-09 of October 18, 2000 (consolidated version as of 07/11/2011) Prudential Control Authority 4 Country ISO Country Responses (Yes/No) 1 00010 00020 00030 Can the head office of your entity have access to information, including personal data, collected by each of the branches located in the country mentioned above, on the operations referred to in Article L. 561-10-2-II of the Monetary and Financial Code? Does the registered office of your entity have access to the information necessary for the organization of vigilance within the group mentioned in Article R. 561-29 of the Monetary and Financial Code, including the exchange of customer information under the conditions provided for by this text? No. Question B2 - Branches - Questions BLANCHIMT Information relating to the system for preventing money laundering and the financing of terrorist activities If your entity has branches in the country mentioned above, in which country do local provisions oppose the implementation of all or part of the obligations mentioned in Article L. 561-34 and Article R. 561-29 of the Monetary and Financial Code? Has your entity ensured that the procedures of point 5 of Article 11-7 of Regulation 97-02 of the CRBF, which provide for the information to be collected and retained for the operations mentioned in Article L. 561-10-2-II of the Monetary and Financial Code, were applied by its branches located in the country mentioned above?

Instruction No. 2000-09 of October 18, 2000 (consolidated version as of 07/11/2011) Prudential Control Authority 5 Country ISO Country Subsidiary Name Responses (Yes/No) 1 00010 00020 00030 Can the head office of your entity have access to information, including personal data, collected by this subsidiary, on the operations referred to in Article L.561-10-2-II of the Monetary and Financial Code? Does the registered office of your entity have access to the information necessary for the organization of vigilance within the group mentioned in Article R. 561-29 of the Monetary and Financial Code, including the exchange of customer information under the conditions provided for by this text? No. Question B3 - Subsidiaries – Questions BLANCHIMT Information relating to the system for preventing money laundering and the financing of terrorist activities If your entity has subsidiaries in the country mentioned above, in which country do local provisions oppose the implementation of all or part of the obligations mentioned in Article L. 561-34 and Article R. 561-29 of the Monetary and Financial Code? Has your entity ensured that the procedures of point 5 of Article 11-7 of Regulation 97-02 of the CRBF, which provide for the information to be collected and retained for the operations mentioned in Article L. 561-10-2-II of the Monetary and Financial Code, were applied by this subsidiary?

Instruction No. 2000-09 of October 18, 2000 (consolidated version as of 07/11/2011) Prudential Control Authority 6 Responses (a): Yes or No (b): Yes or No or Not Applicable 1 I – DESIGNATION OF DECLARANTS AND TRACFIN CORRESPONDENTS

1. Are the names of declarants communicated without delay: (R. 561-23 II) 00010 - to Tracfin? (a) 00020 - to the General Secretariat of the Banking Commission? (a)
2. Are the names of correspondents communicated without delay: (R. 561-24) 00030 - to Tracfin? (a) 00040 - to the General Secretariat of the Banking Commission? (a) 00050
3. Upon modification of the list of correspondents, has your entity's organization allowed it to respond, within the time limits, to Tracfin's requests, in accordance with Article R. 561-24 of the Code Monétaire et Financier? (b) 00060
4. Does the identity of the person or service to contact to make a declaration to Tracfin appear in your entity's internal rules? (a) 00070
5. Any modifications concerning the declarants or Tracfin correspondents occurring during the past fiscal year (designation of new declarants or correspondents, change of contact details, etc.) were they brought without delay to the attention of your entity's agents? (b)
6. In the case where your entity belongs to a financial group: (R. 561-28) 00080 - is the declarant of your entity designated at the group level? (b) 00090 - is the correspondent of your entity designated at the group level? (b) II – SYSTEM FOR DETECTING OPERATIONS MENTIONED IN ARTICLES L.561-15 AND L.561-10-2 II OF THE MONETARY AND FINANCIAL CODE
7. In order to determine whether a suspicious transaction report should be filed or enhanced due diligence performed, do the procedures implemented in your entity provide for gathering information on (Regulation No. 97-02 art.11-7): 00100 - the amount of the operation (in the relevant currency) (a) 00110 - the type of operation (cash deposit, transfer, etc.) (a) 00120 - the existence of an economic justification for the operation (a) 00130 - consistency with the elements collected on the client (a) 00140 - consistency with the object and nature of the business relationship (a) 00150 - the origin of the funds (especially for complex operations) (a) 00160 - the identity of the ordering party or the client (a) 00170 - the identity, if applicable, of the beneficial owner (a) 00180 - the destination of the funds and possibly information on the beneficiary(ies) (a) 00190 - the characteristics of the operation (amount, date...) (a) 00200 - the execution methods of the operation (use of a specific payment system...) (a) 00210
8. Do the procedures implemented by your entity provide that the information obtained regarding the elements of information mentioned in point 1 must be transmitted as part of a suspicious transaction report to Tracfin? (a) 00220
9. Do the procedures implemented by your entity provide for declaring to Tracfin the sums recorded in its books or the operations involving sums that your entity knows, suspects, or has good reason to suspect originate from an offense punishable by imprisonment of more than one year or participate in the financing of terrorism, even if the operation has not been carried out? (L. 561-15) (a) No. Question B4 - Internal Procedures BLANCHIMT Information relating to the system for preventing money laundering and the financing of terrorist activities

Instruction No. 2000-09 of October 18, 2000 (consolidated version as of 07/11/2011) Prudential Control Authority 7 Responses (a): Yes or No (b): Yes or No or Not Applicable 1 00230 4. Do the procedures implemented by your entity provide for declaring operations for which the identity of the ordering party or the beneficial owner or the settlor of a trust fund or any other asset management instrument remains doubtful despite the diligence carried out in accordance with Article L.561-5 of the Monetary and Financial Code? (L. 561-15 IV) (a) 00240 5. Do the procedures implemented by your entity provide for declaring without delay to Tracfin any information element capable of refuting, confirming, or modifying the elements contained in a previous declaration? (L.561-15 V) (a) 00250 6. Do the procedures provide for deferring, when it is possible to suspend the execution of an operation, the execution of this operation, of which your entity knows, suspects, or has good reason to suspect that it is linked to money laundering or terrorist financing, until a declaration has been made to Tracfin? (L.561-16) (b) 00270 8. Has your entity put in place an adapted device for its activities to verify that the client or the beneficial owner is not subject to an asset freeze measure in application of European or national regulations? (Regulation No. 97-02, art.11-7) (a) 00280 9. Does your entity use electronic declaration to transmit its suspicious transaction reports to Tracfin? (a) III – CLIENT AND BENEFICIAL OWNER IDENTIFICATION 00290

1. Before entering into a business relationship with a natural person or assisting them in carrying out a transaction, for cases other than those provided for in Article L 561-9 of the Monetary and Financial Code, is it systematically requested that they present a valid official identity document bearing their photograph? (R. 561-5 1°) (a) 00300
2. Before entering into a business relationship with a legal entity or assisting them in carrying out a transaction, for cases other than those provided for in Article L 561-9 of the Monetary and Financial Code, is it systematically requested the communication of the original or a copy of any act or extract from an official register dated less than three months confirming the name of this legal entity, the legal form, the address of the registered office, and the identity of the partners and corporate officers or their equivalents in foreign law as well as a document attesting to the powers of persons acting on behalf of this legal entity and the presentation of the identity document of these persons? (R. 561-5 2°) (b) 00310
3. Is there an internal procedure establishing the diligence to be implemented regarding the identification of beneficial owners as defined in Articles R. 561-1, R. 561-2, and R. 561-3 of the Monetary and Financial Code? (Regulation No. 97-02 art.11-7) (b)
4. If your entity is a branch of an entity whose head office is located abroad, is your entity in possession of the information elements regarding the identity of all its clients, including those who have opened an account in another entity of the group, for cases other than those provided for in Articles R. 561-15 and R. 561-16 of the Monetary and Financial Code? (L. 561-5) 00320 - in the case where the client has already opened an account in another entity of the group located in France or in another country party to the EEA Agreement (b) 00330 - in the case where the client has already opened an account in an entity of the group located outside the EEA zone (b)
5. If your entity offers the possibility to open an account or carry out any other operation with a client who is not physically present during identification, what measures are systematically implemented among at least one of the following four categories, to ensure the identity of the client: 00340 - obtain additional supporting documents to confirm the client's identity. (R. 561-20 1°) (b) 00350

• implement verification and certification measures of the copy of the valid official identity document or the extract from the official register mentioned in Article R. 561-5 of the Monetary and Financial Code by a third party independent of the person to be identified. (R. 561-20 2°) (b) 00360
• obtain confirmation of the client's identity directly from a person mentioned in points 1 to 6 of Article L. 561-2 of the Monetary and Financial Code established in a Member State of the European Union or in a State party to the Agreement on the European Economic Area or established in a State appearing on the list of Equivalent States taken by decree of the Minister in charge of the economy, which includes in particular the Member States of the international body for consultation and coordination in the fight against money laundering, and which declares applying identification measures equivalent to those of France. (R. 561-20 4°) (b) No. Question B4 - Internal Procedures

Instruction No. 2000-09 of October 18, 2000 (consolidated version as of 07/11/2011) Prudential Control Authority 8 Responses (a): Yes or No (b): Yes or No or Not Applicable 1 00370

• require that the first payment be made from or to an account opened with a financial institution established in a Member State of the European Union or party to the EEA Agreement, as a complementary measure to one of the three measures mentioned above, in the case of account opening. (R. 561-20 3°) (b) 00380

6. Do your entity's procedures provide that the business relationship be terminated when it has not been possible to identify the client, or if applicable the beneficial owner, or to obtain information on the object and nature of the business relationship outside the cases mentioned in Article L.561-9 of the Monetary and Financial Code? (L.561-8) (a) 00390
7. Are documents relating to client identities retained for five years from the closing of their account or the cessation of the business relationship? (L. 561-12) (a) 00400
8. Are documents relating to operations carried out by clients retained for five years from their execution? (L. 561-12) (a) IV – CLIENT IDENTIFICATION – OCCASIONAL CLIENT – AND BENEFICIAL OWNER IF APPLICABLE 00410
9. Does your entity ensure, even in the absence of suspicion of money laundering or terrorist financing, the identity of any natural person, occasional client, who asks it to carry out an operation involving a sum greater than 15,000 euros, to provide a custody service for assets or to carry out a funds transfer operation regardless of the amount, by the presentation by such person of a valid official document bearing their photograph? (R. 561-10 II) (b) 00420
10. Does your entity ensure, even in the absence of suspicion of money laundering or terrorist financing, the identity of any legal person and persons acting on its behalf, occasional client, who asks it to carry out an operation involving a sum greater than 15,000 euros, to provide a custody service for assets or to carry out a funds transfer operation regardless of the amount, by the communication of the original or a copy of any act or extract from an official register dated less than three months confirming the name of this legal person, the legal form, the address of the registered office, and the identity of the partners and corporate officers or their equivalents in foreign law as well as a document attesting to the powers of persons acting on behalf of this legal person and the presentation of the identity document of these persons? (R. 561-10 II) (b) 00430
11. Is there an identification procedure for the beneficial owner of the operation if the person requesting the performance of the same does not appear to be acting for their own account? (R.561-10 II) (b) 00440
12. Is there a procedure for identifying occasional clients who request the performance of several operations between which a link seems to exist and whose total amount exceeds 15,000 euros? (R. 561-10 II) (b) 00450
13. Are documents relating to the identity of occasional clients retained for a period of five years from the cessation of their relationship with your entity? (L.561-12) (b) 00460
14. Are documents relating to operations carried out by occasional clients retained for a period of five years from their execution? (L. 561-12) (b) No. Question B4 - Internal Procedures

Instruction No. 2000-09 of October 18, 2000 (consolidated version as of 07/11/2011) Prudential Control Authority 9 Responses (a): Yes or No (b): Yes or No or Not Applicable 1 00470 V – RISK-BASED APPROACH

1. Is there a procedure indicating, when the risk of money laundering and terrorist financing appears low, the information elements to be collected in application of Article L. 561-6 of the Monetary and Financial Code to verify that the conditions provided for in Article L. 561-9 I of the aforementioned Code are met? (b)
2. Is there a procedure defining: 00480 - the situations in which the risk of money laundering and terrorist financing must be considered high? (L. 561-10-2 I) (a) 00490 - the additional diligence to be applied when the risk appears high in application of Articles L. 561- 10 and L. 561-10-1 of the Monetary and Financial Code? (a)
3. Does your entity apply additional vigilance measures when: 00500 - the client or their legal representative is not physically present for the purpose of identification? (L. 561-10 1°) (b) 00510

• the client is a person residing in another Member State of the European Union or a third country and who is exposed to particular risks due to the political, judicial, or administrative functions they exercise or have exercised on behalf of another State or due to those exercised by direct members of their family or persons known to be closely associated with them? (L. 561-10 2°) (b) 00520 - the product or operation favors anonymity? (L. 561-10 3°) (b) 00530
• the operation is a proprietary or third-party operation carried out with persons natural or legal, including their subsidiaries or establishments, domiciled, registered, or established in a State or territory mentioned in VI of Article L