MEMO DATE: 04-05-01 SFE TO David Burgess A APR 09 2001 ww FROM: Keith Jsper fr ort Arent aa t, 1st inesere OP e Howard Smith nd visited the Miami office ("TRO") of SFIS Tuesday, March 20, 2001, The office is octed inthe Miami Cater building, 201 S. Biscayne Blvd. We met with Executive Director, Nelson Ramiez, and Office Manager Norta Lana. ‘The primary purpose of tho visit was to determine if the TRO was operting witha the confines of a Memorandum of Agreement between Stanford Trust Company Limited ("STC"), Antigua, Wes Indies, and DBF. Our procedures consisted of posing question to Mr. Ramizez and Ms. Llana, general cbservtion, and requesting copies of fe schedules, marketing materials, policies and procedures, and various internal fons, logs, et The quarters consist of approximately 11,000-s9. fof for space located on the 12° floor a the balding. A copy of the lease was nt available. Mr. Ramirez believes the lease was signed some years ago by anther Stanford company, He reported that there are 18 employees, i, executive director, office manager, eleven marketing officers, and five ‘assistants. Ramirez also reported tha there were no aber Stanford Financial Group ("Stanford") companies ot personnel operating ftom within the SFIS office or immediate surrounds. He did sy, however, that a move fo space ‘on the 21* flor of Miami Center is planned for mid-2001, SFIS will thea have very simular space and offices, The ‘ther half ofthe 21" floor willbe occupied by another Stanford company which provides brokerage services Ramirez assared that there would be no shared space cr commoa acess points of Keys, end that ach entity would Ihave separate security systems. There was no signage or osher materials observed inthe TRO office that would lead ‘one to conch thatthe TRO is other than a marketing only oie Asked about the nature of business activities conducted by SFIS, Ramirez assured that there i ct adherence to the terms of the Memorandum of Agreement. He indicated that no account or investment administration activity or ects of discretion are performed or condaced by SFIS or from within fem TRO, all such activity handed in Aatiqua by the "seven or eight” employees OF STC. Asked if we could see cet ile, he indicated that all client files and documents are located at STC and maintained by STC personnel, nol al the TRO or by TRO personne. Ms. Llana provided a copy of a Trensmuinal Log (so Exhibit) that lists tems ‘poached to STC on 3-20-01. She indicates that copies are made of te items incase of loss, and that such copes sre shredded when STC persoanel advise of receipt. 1 was curious about the "envelopes" liste under mmbers 0 and 21 onthe log Ms. Lan explained thatthe names listed are employees of STC and thatthe eavelopes contained non-client related correspondence, magazines, bills payable ete. ‘Mr. Ramirez stated that neither he nor any of the SFIS marketing officers are designated account or investment sxministrators, but that marketing oficers do serve as pints of cons forthe client elationships that they bave individually developed. Ms. Llana indicated that no employees ofthe TRO have online access to client account information including asset listings and transaction histories, and that no employees of te TRO can in any way effect client eccount transactions or change data bases. Such information may only be obtained fiom STC upon request for good reason, Ramirez and Llana report tht they can acces certain managerment reports a regard to clea! accounts, Such isnt available through a Stanford LAN/WAN, bat though internet connect. Marketing officers of course ‘maintain their own “rolodes” information on clients end selationships, ‘We were fumished a copy ofthe Stanford Fiduesary Investor Services In: Manual, Soe Exhibit I. The manual includes job descriptions for ll SFIS personnel, and oulnes a number of policies, procedures abd permed snd non- permined office and officer activities. Although the manval indicates that marketing officers may prepare and execte fiduciary account applications and other documents of bebalfof STC, Mr. Ramirez tates that for actual trustPage? Memo to DT from LK 03.30.01 instruments, such officers may only witness client signatures, not sign on behalf of STC. Trust instruments are ‘reported to be poucked to STC for oficial comporie signature. It should be noted thatthe manual states that "Cosh, ‘money ordes and traveler's checks are not acceptable under any citcumstances” Each cleat is expeesly informed of the cash policy, Soo Exhibit I Ramirez indicted that marketing personne receive an annual base salary pls commision, New accounts ae reported to be subject oa collective consideration process. The marketing officer extend intial consideration which mst be subsequently OK'd by Ramirez, Respective new secount information then goes to STC for final approval, was reported that 99% of STC accounts are revocable trusts, *Single- and malt-purpose sts" are offered. Mult- purpose tusts appear to be more complex and may involve establishment (within the trusts) of Intemational Business Corporations, It seems obvious tat the rust produc available can and mast likely do provide tax havens. I's likely that strict conformity withthe limited seiviies of a TRO would alo serve to ensure that U'S, tox regulations and reporting requirements are averted. Ficy extensive due diligence appears tobe applied by marketing officers and assistants daring the business development sage ‘Asked about STC, Ramizes reported that it manages AUM of approximately $175 milion, some $100 million of that {otal referred by the TRO, He stated that there ae seven or cight employees in Antigua, four of those functioning as fccount administrators. ts quarters are located at 1000 Airport Boulevard, St Johu's, Atigua, West Indies. Its Post Ofice adress is Box 315. Telephone (268) 480-5930, Fax (268) 80-5939, Ho also stated that Miami isthe only "TRO office that hs been established, but hat STC is planning to apply for 2 Texas TRO in the near future. STC's target market is intereational high net-worth individuals. Marketing materials expressly state that SFIS is 2 representative office, and that SIC offers ateratonal ust services to noo-U S. citizens and residents only." STC is sid to have aboard of directors and an sdministrative commitce [Asked about the November 16, 2000 Mami Today news article, Ramite2 indicated thatthe doubling ofthe SFIS ‘presence in downtown Miami was misquoted, He indicated that he “doubling” reresons the move othe 21* oor there the afiated brokerage wil aso be located. He farther indicated that it is amicipated that only tree to five ‘new marketing personel will be added to SFIS, The S10 billion in AUM represents total global holdings managed by Senford. Tht igure is compatible wth figure listed in intemal publications and quoted ina marketing film which ‘we were shown during ou interview. Ramire also stated that the statement that "Welre going tobe able to provide a {ull investment and pavate baking Service forthe intemnational client," reftx o Stanford and not to SFI. He assured that SFIS would continne to only market the services of STC, andor advise clients and potential cents of other services available through Stanford, (Other attachments: [PxhibitIV- packet of marketing brochures, fe schedales, and various intemal forms. [Exhibit V - hardcover book The Sanford Financial Group. Exhibit VI- copy of November 16,2000 iam Today aticle Stanford Pduciary 1 increase staff, consolidate downtown.+ Copy of Tranmial Log dated 3-20-01fee toe 507 remus,EXMIBIT + Copy of Stanford Fciary Investor Services Ine. ManualSTANFORD FIDUCIARY INVESTOR SERVICES INc. A REPRESENTATIVE OFFICE OF ‘STANFORD TRUST COMPANY LTD. MANUALSTANFORD FIDUCIARY INVESTOR SERVICES INC. MANUAL ‘Table of Contents. Introduction Job Descriptions 100 Representative Office Manager ‘Marketing Officer Assistant to the Marketing Officer Receptionist General 200 Kaow Your Customer Office Activities Operations 300 Services and Products Operating Procedures Responsibility. 400 ‘Account Responsibility Miscellaneous 500 Addendum(s) 600 0.80) Exhibits 700 1,11 101, 1V, V, VI Procedure # 1004 100:2 10033 100-4 1005 20:1 20:2 30081 30:2 400:1 50:2 60:1 700:1STANFORD FIDUCIARY INVESTOR SERVICES INC. MANUAL, Table of Contents Introduction Job Descriptions 100 Representative Office Manager Marketing Officer Assistant to the Marketing Officer Receptionist General 200 Know Your Customer Office Activities Operations 300 Services and Products Operating Procedures Responsibility 400 Account Responsibility iscellancous 500 Addendum(s) 600 1u, Exhibits 700 1,0, 11, 1V, V, VI Procedure # 100:1 100.2 1003 1004 1005 2001 2002 3001 3002 4001 S002 60:1 T0041Introduction Stanford Fiduciary Investor Services Inc. is the representative office in the State of Florida for Sanford Trust Company Limited (Antigua) which offers fiduciary services to international investors neither citizens nor residents of the United States. Stanford Fiduciary Investor Services Inc.'s activities in Florida are subject (0 the supervision of the Florida Department of Banking, ‘This manual is the property of Stanford Fiduciary Investor Services Inc. and represents confidential proprietary information. Any dissemination of the contents heteof, except as authorized herein, is prohibited. The cecipient hereof acknowledges the above and acknowledges and agrees that it will surrender same immediately upon demand,ebayJob Description _100:1 (1) ‘TITLE: SUPERVISOR: SALARY STATUS: HOURS OF WORK: DESCRIPTION: DUTIES: Fey REPRESENTATIVE Executive Disector President Exempt The Representative will work a week of forry (40) hours. Overtime may occur due to timing of the workload and travel. (Exempt employees do not get compensation for overtime.) Responsible for administration of company polices, the supervision of the staff, and the activities at Stanford Fiduciary Investor Services Inc. office. 1. Promotes and markets products and seevices of Stanford Trust Company Ltd. by telephone, leter and in person. (Promotion and marketing can be presented only to non- US. citizens or non-residents) 2. Services existing clients of Stanford Trust Company Ltd, receiving, entertaining, ; assisting and visiting them. 3. Provides back-up for other Officers. 4. Coordinates marketing activities of the Marketing Officers 5. Supervises the Marketing Officers and the Office Manager. 6. Responsible for the general administration of the Office.lab Description 100:2 (1) TITLE: SUPERVISOR: SALARY STATUS: HOURS OF WORK: GENERAL DUTIES: DUTIES: 1 2 3, 4 OFFICE MANAGER Office Managee Representative Exempt ‘The Office Manager will work a week of forty (40) hours. Overtime may occur on assigament from the supervisor due to timing of the workload. (Exempt employees do not get compensation for overtime) The Office Manager is responsible for the day to day general administration of the office, and other duties requested by the Representative in a variety of confidential and administeative matters. Responsible for maintaining the most pleasant environment able to assure maximum. performance. Maintaining the highest level of communication among associates to provide suggestions to improve services Perform a permanent quality contol with frequent revisions of all aspects inherent to quality, image, cleanliness, order, funedonality, ete Responsible for general day to day office functions including but not limited to:Job Descdption 1002 (2) ‘Office Manager Inventory control and processing, routine/special supplies equipment requisitions Processing of accounts payable. Negotiating and handling of all services, lease and maintenance contracts and ensuring that all approvals relating to contract, including legal, have been obtained, Supervising all functions related 10 equipment and facility maintenance. At closing of day, shut off equipment, xerox machines, lock cabinets, set answering machine, etc. Pexty Cash responsibility, Reporting to Human Resources Deparument attendance reports Responsible for the maintenance of administrative records, files, et. Responsible for training and supervising the Receptionist. Responsible for the coordination and back-up for the office Adminisuative AssistantsJob Description 100:2 0) (Office Manager Assisting the Repéesentative in his promotional and marketing activity and servicing of existing clients of Stanford ‘Teast Company Led, Daily Activity Report to the Representative. Other duties as requested by the Representative in a variety of confidential administrative detailJob Description 100:3 () TITLE: SUPERVISOR: SALARY STATUS: HOURS OF WORK: DESCRIPTION: SPECIFIC DUT MARKETING OFFICER Senior Vice President of Vice President Representative Exempt ‘The Marketing Officer will work a week of forty (40) hours. Overtime may occur due to timing of the workload and uavel abroad. (Exempt employees do nat gee compensation for overtime.) Markets services and products of Stanford Trust Company Lid. to prospective customers, high net worth individuals or instietions, 1. Prowotes and markers products and services of Stanford Trust Company Led. by telephone, letter and in person. (Promotion and marketing must be presented only 10 non-US. citizens and non-residents 2. Services existing clients of Stanford ‘Trust Company Ltd., receiving, entertaining, assisting and visiting them, 3. Provides back-up for other Macketing Officers. 4. Supervises the Administrative Assistant,job Description 100:4 ( TITLE: SUPERVISOR: SALARY STATUS: HOURS OF WORK: GENERAL DUTIES: DUTIES 1 2 3. 4 5. ASSISTANT TO THE MARKETING OFFICER Administrative Assistant Office Manager Non-Exempt ‘The Administrative Assistant will work a week of forty (40) hours. Overtime may occue on assignment from the supervisor due to timing of workload (with previous approval from management) Standard clecical and secretarial duties to assist the Marketing Officer(s) in his/her/their marketing and promotional functions. Composes and prepases contespondence to prospects and clients of Stanford Trust Company Led Maintains and follows-up prospects lists, etc. Relate and forward to Stanford Trust Company Ltd. main office all requests and instructions received by clients. Serves as back up for the Marketing Officer(s) in all client contacts. Assist che Marketing Officer) ia the preparation of his/her/ their marketing tipsJob Description 100:4 2) ‘Asrntant 10 Matketing Officer 6 Under the coordination and supervision of the Office Manager, serves as back up for other Marketing Officer Assistants and relief for the Executive Receptionist. Punctuality and attendance essential to this position. Other duties as assigned by the Office Manager.fob Description 100:5 (1) SUPERVISOR: SALARY STATUS: HOURS OF WORK: GENERAL DUTIES: DUTIES: RECEPTIONIST Office Manager Non-Bxempt ‘The Receptionist will work a week of forty (40) hours. Overtime may occur on assigament from the supervisor due to timing ‘of workload. (with previous approval from management) The employee performs the activities of a front desk receptionist, and other administrative duties to assist the Office Manager. 1, Answers and disects telephone calls 2 Greets visitors, welcomes and directs them to the Officers, 3. Dates and distributes all incoming correspondence. Maintains certified mail and courier registers. Sends ‘outgoing packages with local courier or messengers. 4, Assists Office Manager in the preparation of correspondence to suppliers, contractors, etc 5. Maintain files, logs and lists related to Accounts Payable and the inventory of office supplies.Job Description 1005 (2) Receptionist Fenn 97 Serves as back up for Administrative Assistant. Other related duties as assigned by the Office Manager.Genes 12Know Your Customer 200:1 (1) 1 1 INTRODUCTION ‘As representatives of Stanford Teust Company Led, Stanford Fiduciary Investor Services Inc. promoting fiduciary products and services, it is extremely important that we provide as much information as possible regacding the potential clients which we sefer to Stanford Trust ‘Company Lid. Further, our collection, verification and documentation relative t0 potential clients will greatly assist Stanford Trust Company Ltd. and the financial instiutions whese ulimately the assets of the clients will be placed, in the avoidance, detection and prevention of money laundering or other illicit activities. Accordingly, Stanford Fiduciary Investor Services Inc. has adopted the following guidelines. KNOW YOUR CLIENT One of the most important, if not the most important, means by which can be avoided, criminal exposure to Stanford Trust Company Led. whose resources are used by customer with ice purposes, is to have @ clear and concise understending of the customer's practices, The adoption of “know your customes” guidelines or procedures by financial institutions has proven quite effective in detetisg suspicious activity A. Identifying the Customer ‘As a general rule, a Gduciary relationship should never be established until the identity of 2 potential customer is satisactonly established. The importance of personal visits by the Marketing Officers to potential and existing customers can not be over emphasized. If 2 potential customer refuses to produce any of the requested information, the relationship should not be established. Likewise, if requested to follow-up information is not forthcoming, any relationship already begun should be terminated The following is an overview of general principles to follow in establishing fiduciary relationships: sista rsKnow Your Customec 2001 @) 1 Individuals a) b) a) 5 No fiduciary account is to be referred to Stanford Trust Company Ltd. without satisfactory official identification, such as, a passport or registration card of all the beneficiasies (primary and ultimate). ‘This identification must show the person’s name, photo, signature and number of identification, No fiduciary account can be opened if the proposed asset amount and the anticipated activity appear not consistent with information provided by the client. Also it must be substantiated that the client is involved in legitimate activites and that his/her income and wealth has a legitimate base. For prospective clients known only through promotional means a least evo (2) wetten banking references or letess from reputable lawyers, stockbrokers or accountants must be submited For prospective clients known by the Marketing Officer for more than one (1) year, an Officer's Memorandum stating the customer’s integrity, responsibilty and the Officer's assessment of this person must be submitted. For prospective clients known for less than one (1) year, an Officer’s Memorandum and one (1) reference letter, from a bank, a reputable lawyer, ‘accountant or stockbroker, must be submitted. A client may be a referral from an employee or one of Stanford Trust Company LTD’s clients. In this instance, « refecal alone is not sufficient to identify the client, but in most instances it should warcant less vigilance than otherwise requiredKaow Your Customer 200:1 (3) 2. Business a) by 4) ° 6 8) Business principals must provide evidence of legal status (eg. sole propriorship, partnership, or incorporation or association) when opening a Sduciay relationship in the name of such business. Establish the identity of all the principals of the business. Fi is an International Business Company (IBC) or a Personal Investment Company (PIC), a cerdficate of Good Standing, as well as copies of Certificate of Incorporation and Articles of Association, must be submitted. If it is a commercial enterprise, check the name of the business with a reporting agency or check prior bank references, Follow up with calls to the customer's business (Thanking the customer for opening the account, for example). Disconnected phone service warrants further investigation As soon as possible, perform a visual check of the business to verify the actual existence of the business and the size of its activities and resources. Obtain Ginancial statements, No fiduciary account can be opened if the proposed asset amount and the anticipated activity appear not consistent with information provided by the client Also it must be substantiated that the client is involved in legitimate activities and that his/her income and wealth has 2 legitimate base,Kaow Your Customer 200:1 (4) Il SUSPICIOUS CONDUCT AND TRANSACTION In making 2 detecmination as to the validity of a client, theze are certain categories of activities that ace suspicious in natuce and should alert the Macketing Officer as to the potential of the elient to conduct illegal activities at our Institution, The categories, broadly defined, are: 1. Insufficient, false, or suspicious, information provided by the client 2 Assets, which are not consisient with the business activities of the client, or deposits by parties, unrelated to the applicant. Wire transfer activity, which is not consistent with che business activities of the client. 4. Structuring of transactions to evade recordkeeping and/or reporting requirements. 5. Funds transfers to foreign countries nor elated wo the business activity of the client, 6. Structure or promise of deposits based on loan transactions, IV. DUE DILIGENCE DOCUMENTATION Keep in mind that in many instances legitimate clients may structure transactions for valid business reasons in a fashion that may appear to have the characteristics of a suspicious or illegal transaction. It is at this point that our personal knowledge of the client, his business and typical tansaction and documentation will ’be most helpful to make its determinations. Accordingly, to assist in documenting personal knowledge and due diligence, Marketing Officers should utilize and give particular attention to the completion of the following formsKnow Your Customer 200: (5) 1 DUE DILIGENCE REPORT [Exhibit 700:1 1} Must be provided to the head office of Stanford Trust Company Led. together with the opening documents and initial deposit. Stanford Trust Company Led. will noc consider the establishment of any fiduciary account until receipt of the Due Diligence Report duly completed and signed by the Marketing Officer. OFFICER'S MEMORANDUM [Exhibit 700:1 (V)] Muse be prepared by the Marketing Officer in lieu of reference letters from thied parties (banks, lawyers, etc.) ‘when the prospective client has been known for more than. cone (1) yeas. In case that the prospective client has been known for less than one (1) year, together with the MEMORANDUM, one (1) reference letter (from a bank, lawyer, stockbroker of accountant) must be submited. ‘The MEMORANDUM must substantiate the Client's integrity, responsibility and trustwosthiness. CALL REPORT [Exhibit 70081 (VD) ach visit paid to a client or seceived at the office must be documented dheough a brief call report that must be filed within the Clients folder at the head office of Stanford ‘Teast Company Led. in Antigua ‘TRIP REPORT [Exhibit 700: (VID] Original to the Executive Director. IV MISCELLANEOUS A, Mailing of promotional materials 1 In all instances where promotional materials are being sent to prospective clients, especially where requests forKaow Your Customer 200: (6) Information has not oxiginated from a referral or a Marketing Officer's efforts, discretion and prudence should be utilized 2 Use of promotional material and stationery to perpetcate frauds has unfortunately become increasingly common place. Accordingly, we should be exteemely vigilant in those circumstances, which do not seem appropriate or customary. Mailings to P.O. boxes should not be made unless the Marketing Officer knows the individual or entity and the Masketing Officer: (a) obtains a phone number and vecfies the identity of the individual prior to sending and (b) obtains a physical address. In addition, inquities, from countries or areas not usually marketed or serviced by the Officer or requests accompanied by promise of large deposits or transactions, should prompt the Officer to give ‘greater scrutiny to the situation and prospective customer.1 PERMISSIBLE A Matketing Officers may meet, correspond and communicate with ‘customers or potential customers of Stanford Trust Company Led. Marketing Officers may have available in the office ot on theit person, and provide to customers, or prospective customess (10 solicit new fiduciary accounts), information as to the different investment products available for customers of Stanford Teust Company Ltd, through other entities, including entities affiliated through substantia! ultimate common ownership (.¢., Stanford Group Company, Stanford International Bank, etc). This information can include brochures on the entire Stanford Group of Companies, or on individual companies in the group, as well 2s unaffiliated companies through or together, with the Stanford. ‘Trust Company Ltd’s products or services are offered. Do document for files and records that the administration and discretionary decision-making on trust accounts take place at the head office of Stars(ord Trust Company Lud, is Antigua Macketing Oficers may prepare and execute Bduciary applications and other documents with customers on behalf of the Stanford ‘Trust Company Led., and accept checks, secutties or other assets to be forwarded to Stanford Trust Company Led, and to receive checks, securities, or other assets for customers’ from Stanford Trust Company. Cash, money orders and uaveler’s checks are not accepuble under any circumstances. Officers must make clear to the client that they cannot bind Stanford Trust Company Lid - Antigua and such services are solely for customer's convenience Marketing Officers must make it clear to customers and prospective clients thar they work for and are legally authorized to repcesent, in certain matters, only Stanford Trust Company,Office Activites 20022 @) F In carrying out fiduciary duties on behalf of the Stanford Trust Company, Marketing Officers. may contact and facilitate communications between customers and any company Gncluding ‘companies affiliated by substantial ultimate common ownership, like Stanford Group Company or Stanford International Bank) ‘where investments held in trust by Stanford Teust Company Ltd. are located, or to which they are to be sent as contemplated by the trust agreement. Marketing Officers may, on behalf of a customer or prospective customer of Stanford Trust Company Ltd, ~ but not on behalf of other people — obtain rate quotes and other information from any company, including Stanford Group Company or Stanford International Bank. Marketing Officers can respond to customer's inquiries by communicating with persons or encies involved in trust accounts established at Stanford Trust Company Led Marketing Officers can provide information to existing customers ‘concerning their trust accounts, reviewing past investment decisions and investment performance 1 NOT ACCEPTABLE A Marketing Officers cannot deal with Stanford International Bank or any other Stanford Company on behalf of persons who are not customers of Stanford Trust Company Ltd. However, Marketing Officers may advise any such persons how they may themselves contact the Bank, or the other company, and obtain any information. * Macketing Officers cannot offer or market to customers oF potential customers products or services offered by any company (including Stanford International Bank) othe than through Stanford Trust Company Ltd. AU products and services must be ‘offeced in the context of an existing or proposed trust cladonship with Stanford Trust Company LedOffice Activites 2002 (3) c Marketing Officers cannot hold themselves out as the representative or agent of any company other than Stanford Trust Company Led. Macketing Officers cannot accept any money to be deposited with Stanford Intemational Bank, or any other financial institution, other than through 2 trust with Stanford Trust Company Ltd. Macketing Officers cannot solicit business of any nature for any company, other than Stanford Trust Company. In particular, they cannot solicit business on behalf of Stanford International Bank or Stanford Group Company. ‘Marketing Officers cannot help any company other than the Stanford Trust Company Led. to engage in any business of any nature whatsoever, unless that business involves a trust relationship through Stanford Trust Company Led. Matketing Officers cannot engage in administrative, data processing, cecordkeeping or other “back-office” activities on behalf of any company other than Stanford Fiduciaty Investor Seevices Ine Stanford Fiduciary Investor Services Inc. and/or any of its Matketing Officer cannot act as: 4 Trustee, committee, guardian, custodian, conservator or other persona representative of a person, property of aa estate b. Registrar or transfer agent of stock notes or bonds. Fiscal or financial agency. 4. Investment advisor. & Trustee in bankruptcy or assignee for creditors,Office Activies 2002 (4) 1 etna 5199 Stanford Fiduciary Investor Services, Inc. and /or any ofits Marketing Officers cannot conduct discretionary investment activites, including any of the following, when done on a disceetionary basis execution of buy and sell orders b. selection of securities for customer's accounts ©. collection of dividends and interest, periodic deposit of income to an account, remittance to customers or reinvestment d. bookkeeping (other than appropriate record keeping for Stanford Fiduciary Investor Services Inc), receipt of deposits, and exchange or delivery of securities (except as. provided in 1) D. above) © receipt of annuities, rents, royalties, or similar payments, except to forward such items to Stanford Trust Company Led or to irs customers upon request of customers of Stanford Trust Company Led, £ safekeeping of securities except as provided in 1) D. above) & purchase and sale of securities, physical possession thereof, related bookkeeping and collection functions h. effecting client transactions, such as trading or buying stock or closing a transaction i, acting as an investment advisor, and j. performing acts of discretion regarding any Siduciay account, including daily administration of accounts, ™Otlice Activites 2002 (5) J. Marketing Officers or any Stanford Fiduciary Investor Services Inc. employee shall not have or exercise discretionary signatory authority on behalf of Stanford Trust Company Led. regarding any customer account or related matter.Operations 300Services and Products 30:1 (1) I Ta SINGLE PURPOSE TRUST ‘A. To manage a fiduciary account with assets deposited at Stanford International Bank only B. Hold mail services SINGLE PURPOSE TRUST ‘A. To manage a fiduciary account with assets deposited at Stanford International Bank only. B. Ancillary Services: Hold Mail, Bill Paying, Credit Cards, ete Mh SINGLE PURPOSE TRUST A. To manage fiduciary accounts with assets deposited/invested at one or mote Stanford Instirutions B. Ancillary Services: Hold Mail, Bll Paying, Credit Cards, et I MULTI-PURPOSE TRUST, TESTAMENTARY TRUST ‘A. To manage fiduciary accounts with assets distributed at one or ‘more institutions. B, LBC. Gnternational Business Company) or P.LC. (Personal Investment Company) C Nominee Officers and Disectors D, Ancillary services: Hold Mail, Bill Paying, Credit Cards, ec IV PERSONAL HOLDIN' B ‘A, Incorporation of an B.C. (International Business Company) ot PLLC (Personal Investment Company) B. Nominee Officers and Disectors sta aOperating Procedures _300:2 (1) I NEWRELATIONSHIP To refer a new relationship to Stanford Trust Company Ltd., the Marketing Officer must have completed the documents listed below and forwarded to the head office in Antigua by international courier: 1. a) b) <) APPLICATION FOR A FIDUCIARY ACCOUNT form (Single Puspose Trust) [Exhibit 700:1 ()] APPLICATION FORM ([aternationsl Business Company) [Exhibie 700-1 (DJ or MEMORANDUM OF WISHES — (multipurpose/ testamentary trust) fin the form of a letter signed by the applicand] 2 DUE DILIGENCE REPORT (Exhibit 700:1 (I)} prepared, signed and dated by the Marketing Officer. 3. A PHOTOCOPY OF THE PASSPORT or other legal document evidencing identity of all beneficiaries (primary and ultimate). This photocopy will show the person’s name, photo, signature, and number of identification, b) c) Eom ‘TWO WRITTEN BANKING REFERENCES or reference leters from lawyers, accountants, etc. for the applicant(s) primary beneficiay(ies) in the case that the applicancs) is nat a referral from an Officer of Stanford Trust Company Ltd. ONE WRITTEN REFERENCE LETTER is sufficient when the prospective cient has been known (for less than cone year) by the seferring Marketing Officer and an OFFICER'S MEMORANDUM is submitted. NO REFERENCE LETTERS are requested when the prospective client has been known for more than one year and an OFFICER'S MEMORANDUM is submitted,Operating Proceduces 3002 (2) 5. An OFFICER'S MEMORANDUM [Exhibit 700:1 (¥)], prepated and signed by the refercing Marketing Officer is submitted in licu of reference letters. The Resume will state the client's integrity, responsibility, and reputation 6. CHECK CONFIRMATION (Exhibit 700:1 @V)) — accompanying any check received from the. applicant (Odiginal to be given to the applicant as receipt. Two copies sent to Antigua head office) (Cash, money orders or traveler's checks axe aot acceptable uundet any ciscumstances. Officers must make cleat 0 the clients that they cannot bind Stanford Trust Company Led ~ Antigua and such services are solely for ‘customer's 7, FIDUCIARY AGREEMENT Once the fiduciary account has been approved and accepted by Stanford Trust Company Ltd, a Fiduciary Agreement (in two originals) will be prepared by Stanford Trust Company Ltd. and forwarded to the client, directly or through the Marketing Officer. One original, duly signed by the client, will be renurned to the Head Office for the client file MI EXISTING RELATIONSHIP All and any documents received from existing clients, including checks for deposit to the Trust account, letters of instruction, letters of authorization, etc, must be forwarded to the head office in innamediately by fax and at the end of the day by cousiex. Cash, money orders or taveler’s checks are not acceptable under any ciacumstances Antigua A CALL REPORT will be prepared and sent to Stanford Trust Company Ltd.-Antigua to be kept with the client's fle for any visit paid {0 or received from the client