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filed. As mentioned earlier, we may share with the clearing broker a copy of the filed SAR-SF – unless it would be
inappropriate to do so under the circumstances, such as where we file a SAR-SF concerning the clearing broker or
its employees.

Responsibility for AML Records and SAR Filing
Our AML Compliance Officer and his or her designee will be responsible to ensure that AML records are
maintained properly and that SARs are filed as required. We will maintain AML records and their accompanying
documentation for at least five years. We will keep other documents according to existing BSA and other record
keeping requirements.

Approval & Signatures

Approve the firm’s AML program by signing below.

I have approved this AML program as reasonably designed to achieve and monitor our firm’s ongoing compliance
with the requirements of the BSA and the implementing regulations under it.

Supervisor Name: John Riley

Supervisor Signature Date 10-10-2020

AML Compliance Officer Approval

Approve the firm’s AML program and agree to enforce it by signing below.

I have approved this AML program as reasonably designed to achieve and monitor our firm’s ongoing compliance
with the requirements of the BSA and the implementing regulations under it. I am assuming full responsibility for
the firm’s AML program. I am qualified by experience, knowledge and training. I understand the duties listed under
the program and will fulfill those duties.

AML Officer Name: John Riley

Supervisor Signature Date 10-10-2020