Annual RIA Anti-Money Laundering Certification

On behalf of ___________________________(the “Firm”), I certify that as of the date set forth below and for as long as the Firm remains a customer of Troika Dialog USA, the Firm shall comply with the statements set forth below:

1. The Firm obtains and maintains documents and information identifying those persons, including the executive officers, directors, managing members or control persons of any entities (collectively the “Principal”), for whom it may act as nominee when effecting transactions in securities listed or traded;

2. The Firm has AML procedures in place to monitor that the assets of any Principals have not been derived from any illegal activity;

3. None of the Principals are involved in illegal activities;

4. None of the Accounts are subject to blocking requirements under any laws or regulations of the United States, such as regulations administered by the Office of Foreign Assets Control of the United States Department of Treasury (“OFAC”)’

5. None of the Principals:

a. appear on a list of those persons or organizations designated as either “Terrorists”, “Specially Designated Nationals and Blocked Persons” or other similar lists currently maintained by OFAC;

b. is a citizen or resident of a country or region included in OFAC’s list of embargoed countries and regions;

6. None of the Principals or Accounts are that of foreign banks (i.e. organized under the laws of any country other than the United States) with no actual physical presence in the country in which the foreign bank is permitted to do business;

7. All of the Principals are residents of countries that are members of the Financial Action Task Force on Money Laundering (“FATF”);

8. The Firm shall promptly advise Troika Dialog USA of any facts and circumstances that contravene any of paragraphs 1 – 7 above. The Firm acknowledges that, upon receipt of such information, Troika Dialog USA, may take any one or combination of the following actions: (i) filing a Suspicious Activity Report with the Financial Crimes Enforcement Network or other required report(s) as required by United States law and regulations; (ii) blocking access to the Troika Dialog USA,, systems; (iii) refusing to accept additional orders on behalf of a Principal; or (iv) otherwise freezing the assets of a Subscriber to the extent that Troika Dialog USA has access to said assets.

Firm Name: ____________________________________________

Signature of Authorized Signatory: ______________________________ Date: _________

Print Name: _______________________________

Title: ____________________________