Declaration on Money Laundering Prevention / USA Patriot Act

Affirmation of measures towards preventing money laundering,
general information on SPARKASSE OSNABRÜCK's correspondence bank
accounts

We, Sparkasse Osnabrück, herewith certify that we are a banking institution licensed by Germany's Federal Financial Supervisory Authority (BaFin) and subject to said body's supervisory regulations.

Furthermore, we herewith affirm that our bank has and utilizes the means, resources and internal procedures to track down and deter money laundering activities relating to the financing of and gains from terrorist activities, organized crime or other serious criminal offences.

The German Money Laundering Act (Geldwäschegesetz - GwG) has been in force since 1993 and since then has been updated several times, in particular as result of the "40 recommendations" put forward by the "Financial Action Task Force on Money Laundering" (FATF) as well as European Community Council Directive 91/308/EEC (amended by way of EC Directive 2001/97/EC) on preventing use of the financial system for the purposes of money laundering. The statutory obligations arising from the aforementioned German Money Laundering Act are explained in corresponding administrative regulations of the BaFin (www.bafin.de).

Both the Money Laundering Act as well as the guidelines laid down by the BaFin obligate banking and financial service institutions to draw up and implement internal regulations and to take precautionary measures for the purposes of preventing money laundering. Compliance with the resultant obligations forms an integral element of SPARKASSE OSNABRÜCK's business policy.

In accordance with Article 25 c (4) of the Credit Services Act (CSA),  SPARKASSE OSNABRÜCK has appointed a Money Laundering Officer whose responsibility is to ensure the proper implementation of the regulations and obligations specified by the Money Laundering Act and of the administrative rules and regulations enacted by the BaFin in respect of said implementation.

The Money Laundering Officer has drawn up in-house organizational and working instructions for the employees of SPARKASSE OSNABRÜCK that encompass the obligations to be met in line with the Money Laundering Act and in-house rules and principles. In particular, regular training is ensured for SPARKASSE OSNABRÜCK's personnel by way of which they are informed and kept up-to-date on money laundering methods and the catalogue of obligations laid down by the Money Laundering Act. In addition, the employees are given regular reliability checks.

In addition to these measures we check the identity of our customers on the basis of probative documents. To the extent that we are obligated to perform legitimation checks, we also ascertain the identities of commercially authorized persons, in other words those persons on whose behalf the transaction in question is taking place or who is party to this transaction as trustor. In cases of doubt as to whether the person to be identified is acting on his/her own account or in cases in which it is ascertained that he/she is not acting on his/her own account we then take appropriate steps in order to gain information on the actual identity of the person on whose behalf the customer is acting.

In-house and external auditors perform annual audits to ascertain whether the security measures taken towards the prevention of money laundering at SPARKASSE OSNABRÜCK are effective and adequate and whether the Money Laundering Officer is fulfilling the duties with which he has been entrusted.

SPARKASSE OSNABRÜCK has in place and operates an electronically supported research system that monitors account-based financial transactions for unusual, irregular and unexpected activities. In the event that justified reasons for suspecting money laundering activity still remain despite intensive clarification and monitoring of the business relationship with account being taken of the transaction and of the customer's person or the source of his/her assets, we refrain from the transaction in question and decide as to whether to refuse or break off the business relationship. Additionally, we report cases of suspicion to the relevant law enforcement agency in accordance with Article 11 of the Money Laundering Act.

In conclusion, we herewith certify that SPARKASSE OSNABRÜCK is not a shell bank (in other words a bank that does not have a physical presence and is unaffiliated with a regulated financial group) within the meaning of the USA Patriot Act and that we do not conduct or maintain any business relationships with shell banks.We, SPARKASSE OSNABRÜCK, do not have correspondence banks on our own. We use the whole range of correspondence banks of Norddeutsche Landesbank – Girozentrale, Hanover/Germany,SWIFT: NOLADE2H, Internet: http://www.nordlb.de