In addition to agent recruitment and termination procedures, the company has developed procedures to manage risk of working through agents by training agents, managing agent relationships, monitoring agent relationships for potentially suspicious activity, and for the termination of agent agreements.

The Company understands that such procedures are critical to helping protect it from being used unknowingly by its agents to facilitate money laundering and/or terrorist financing. The Compliance Officer subsequently monitors agent activities for compliance with the terms of the agent agreement and for potentially suspicious transaction activities.