In consideration of PDQ ATS, Inc. ("PDQ") facilitating orders on behalf of its Customers and/or their customers/clients, by using the PDQ System each Customer approved to use the PDQ System agrees and confirms that:

(i) It is a financial institution regulated by a Federal functional regulator (which includes, among others, a broker-dealer registered with the Securities and Exchange Commission).

(ii) It has established and has in effect, and agrees to maintain, written anti-money laundering ("AML") policies and procedures that comply with the USA Patriot Act of 2001 and the Bank Secrecy Act (31 U.S.C. 5311, et seq.) (together, the "AML Laws"), to the extent applicable.

(iii) Its AML policies and procedures meet or exceed the requirements of the AML Laws.

(iv) It will designate, and identify to PDQ (by name, title, mailing address, e-mail address, telephone number, and facsimile number), a person or persons responsible for implementing and monitoring the day-to-day operations and internal controls of the AML program and provide prompt notification to PDQ regarding any change in such designation(s).

(v) With respect to each customer/client account or sub-account that Customer introduces to PDQ:

• Customer is acting as an intermediary or nominee for the customer/client.
• Pursuant to Customer's AML policies and procedures, Customer has in place policies and procedures that verify the identity of the customer/client, and if not an individual, its beneficial owners; that can be reasonably expected to detect and cause the reporting of transactions required under 31 U.S.C. 5318(g) and the implementing regulations thereunder, as applicable, and that are reasonably designed to achieve compliance with the Bank Secrecy Act and the implementing regulations thereunder, as applicable.
• Pursuant to Customer's policies and procedures, Customer has taken or will take reasonable steps to verify that Customer has not received money or securities from any illicit activity from the customer/client.
• To Customer's knowledge, each of Customer is customers/clients, and, if the customer/client is not an individual, its beneficial owners, that are involved in transactions through PDQ is not: (i) a terrorist, (ii) a terrorist organization, (iii) an other prohibited party on the Treasury Department's Office of Foreign Assets Control ("OFAC") Specially Designated Nations list, or (iv) from a country that is subject to an embargo enforced by OFAC.
• Pursuant to Customer's AML policies and procedures, Customer retains records and documentation of its AML compliance activities for a period of at least five years, as applicable.

Upon request, Customer agrees that it will certify to PDQ that it has implemented its AML policies and procedures and that Customer or its agent performs the requirements of such AML policies and procedures.

Customer authorizes PDQ, upon PDQ's request, to monitor on a periodic basis various aspects of Customer's compliance with the customer identification and verification duties and procedures required of Customer.

In the event that any of the provisions of this Policy conflict with any of the provisions of an applicable self-regulatory organization's rule requiring the development and implementation of an AML compliance program, the provisions of the rule of the Customer's designated examining authority shall apply.