Morgan Mill Metals Suppliers and Purchasers of Precious Metal

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.