Presentations - Inaugural Conference with Financial Institutions

OPERATIONAL STRUCTURE RISK MANAGEMENT METHODOLOGY

• SEPARATE UNIT WAS FORMED TO TREAT SOLELY WITH MEDICAL CANNABIS. THIS WAS DONE TO AVOID CONTAMINATION WITH THE OTHER BANKING SERVICES WE OFFER. THERE ARE 3 FULL TIME STAFF INCLUDING A SENIOR OFFICER WHO REPORTS DIRECTLY TO SENIOR MANAGEMENT

• AS A SECOND LINE OF DEFENCE ANOTHER KEY ROLE WAS CREATED IN THE COMPLIANCE DEPARTMENT TO MONITOR SPECIFICALLY THE ACTIVITIES OF THE SECTOR

• THE INFORMATION SYSTEM HAD TO BE SPECIFICALLY REDESIGNED TO FACILITATE ENHANCED MONITORING OF THE PORTFOLIO AS WELL AS TO ENSURE THAT ALL EDD MEASURES AND PROHIBITIONS WERE CAPTURED AND ENFORCED

• DUE DILIGENCE IS PERFORMED BEFORE ACCEPTING WIRE TRANSFERS

• PROHIBITIONS AND EXCEPTIONS ARE CLEARLY OUTLINED TO THE CUSTOMER IN THE FORM OF AN OFFER LETTER

• THE BANK, AT THIS TIME, HAS NOT DONE ANY ON-BOARDING OF LICENSE HOLDERS BUT PAYMENTS FOR LICENSES ARE BEING PROCESSED THROUGH OUR CANADIAN CORRESPONDENT