Anti-money laundering program requirements:

Each dealer shall develop a written anti-money laundering program reasonably designed to prevent the dealer from being used to facilitate money laundering.

The program must be approved by senior management.

The program must be available to the Dept of Treasury through FinCEN or its designee upon request.

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Morgan Mill Metals considers the "Morgan Mill Metals Anti Money-Laundering Program essential for performing business as a method of complying fully with the January 1, 2006 USA PATRIOT Act requirements. The Act provides great investigative authority to the Department of Treasury FinCEN, Financial Crime Enforcement Network. The Act contains provisions for substantial fines, penalties and seizures of asset for violators. Precious metal refiners choosing not comply with the Act, place jewelers, dental labs and other companies they conduct business with under the risk of investigation from the FinCEN. Jewelers and dental labs conducting business with refiners not in compliance with the USA PATRIOT Act may place their assets under risk of seizure from the FinCEN.

For the purpose of simplifying the determination of compliance of this program to the Act, the Code of Federal Regulations, CFR location is provided prior to each section designed to comply with the specific regulations given at that location. Although not required by the Act, Morgan Mill Metals will maintain on file, reports completed in this program for 30 years.

31 CFR 130.140(a)

Definitions:

Dealer: For the purposes of Morgan Mill Metals: A person engaged within the United States as a business in the purchase of more than $50,000 and sale of more than $50,000 of covered goods per year.

Covered Goods: For the purposes of Morgan Mill Metals: Precious metal, jewels, and precious stones.

Precious metal: For the purposes of Morgan Mill Metals: Gold, iridium, osmium, palladium, platinum, rhodium, ruthenium, or silver, having a level of purity of 500 or more parts per thousand.

Jewel: For the purposes of Morgan Mill Metals: Organic substance with gem quality market-recognized beauty, rarity, and value, and includes pearl, amber, and coral.

Precious stone: For the purposes of Morgan Mill Metals: A substance with gem quality market-recognized beauty, rarity, and value, and includes diamond, corundum (including rubies and sapphires), beryl (including emeralds and aquamarines), chrysoberyl, sopinel, topaz, zircon, tourmaline, garnet, crystalline and cryptocrystalline quartz, olivine peridot, tanzanite, jadeite jade, nephrite jade, spodumene, feldspar, turquoise, lapids, lazuli, and opal.

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The following should be taken into consideration for any and all business transactions with Morgan Mill Metals, including new and repeat customers:

Morgan Mill Metals is required to inform a USA PATRIOT Act Compliance Officer, should a transaction be deemed suspicious by an employee. Suspicious transactions include, but are not limited to acts of money laundering or terrorist financing. This notification must be made in writing, using the Appendix F - Suspicious Activity Report Form. The Compliance officer or his designee must investigate the potential transaction and make a written determination regarding the Suspicious Activity Report Form, and the potential for the transaction to be used as a tool for money laundering or terrorist financing. The written determination must include a ruling as to whether the transaction will be honored, and if the FinCEN will be notified. The following transactions may be considered suspect by a Morgan Mill Metals employee, in conjunction with the USA PATRIOT Act:

1. Unusual payment methods to Morgan Mill Metals by a purchaser of precious metal. (Examples include: Sequentially numbered money orders, cashiers checks and payments to third parties).
2. Attempts by a buyer or seller of precious metal or gems to maintain an unusual degree of secrecy with respect to the transaction.
3. Request for settlements that are unusual for the particular customer.
4. Settlements which do not conform to standard industry practices.
5. In the event a business or individual request multiple checks to be issued for the payment of one settlement, the business or individual must be questioned regarding the reason for the request. In order for Morgan Mill Metals to honor this type of request, the business or individual must provide a reason not related to the avoidance of taxation. The reason for the request must be recorded on the CMIS and the Appendix F - Suspicious Activity Report Form.
6. Until further notice, Morgan Mill Metals will not conduct business with any business or individual who:
   1. Require payments be made to a financial institution located in the Cayman Islands.
   2. Are located in the United States and require payments to a financial institution not located within the United States.
   3. Are located in any jurisdiction listed in Table - A of this program.
7. Are involved in any activity or requested activity not listed above from a purchaser or seller of precious metal, which may be determined to provide money-laundering or terrorist financing opportunities.

Bank Secrecy Act

In the event Morgan Mill Metals receives currency in excess of $10,000, in one transaction or two or more related transactions, a report of the information with respect to the receipt of currency must be made using Appendix (G), IRS Form 8300 and instructions. Transactions are considered related when occurring within a 24-hour period to one another, or if the recipient knows, or has reason to know each transaction is one of a series of related transactions. For the purpose of this program, cash is defined as follows (a complete definition of cash is provided in the IRS Instructions to IRS Form 8300):

U.S. and foreign currency received in any transaction.

A cashier's check, money order or bank draft having a face value of $10,000 or less, received in any transaction in which the recipient knows the instrument is being used in attempt to avoid the reporting of the transaction.