EFTA Document EFTA01298708

NAME SEARCHED: The Financial Trust Company PWM BIS-RESEARCH performed due diligence research in accordance with the standards set by AML Compliance for your business. We completed thorough searches on your subject name(s) in the required databases and have attached the search results under the correct heading below. Significant negative media results may require escalation to senior business. Legal and Comp iance management. Also, all accounts invoking PEPs must be escalated. Search: Result: Click hem for results: Reviewer Comments (as necessary): RDC .:4 No I lit 0 Not Required Hit I. RDC Results No RDC Alert (Please See Attached) • FIRCOSOFT i.74 No Hit U Not Required Hit II. FIRCOSOFT Results No FIRCOSOFT Alert (Please See Attached) M BIS Igi Yes 0 No 0 Not Required Iti. Negative Media N No Information Found IV. Non-Negative Media Information Found (Please See Attached) V. Other Language Media llot Required 1MB Remits? 0 VI. D&B Information Found (Please See Attached) Yes O14o Not Required SMARTLINX Results? VII. Smanlinx No Information Found 0 Yes i.7.! No 0 Not Required COURT CASES C4 Review by Legal May be VIII. Court CITA Information Found (Please See Attached) Required 0 No Results Search not required • Prepared by: Himanshu IChandehval Date: 10/15/2018 Research Analyst Instructions: I. Review and confirm that all results are returned for your client. 2. Please note that you are still required to perform any Martindale-Hubbell search (if applicable) on each search subject. We have attached the web link below for your convenience:Martindale-HubbellhttpdArtvw.martindale.comhp/Martindakihorne. ml 3. As needed, provide comment for any negative results. 4. If applicable, please obtain clearance from Compliance for all alerts. 5. Save any changes you make to this document and attach file to your KYC. For internal use only For internal use only CONFIDENTIAL — PURSUANT TO FED. R. CRIM. P. 6(e) CONFIDENTIAL SbNY_0M_00063635 DB-SDNY-0026460 EFTA 00174143 EFTA01298708 Please note: Submission of a signed KYC is your confirmation that you have fully reviewed the research documents. For internal use only For internal use only SDNY_GM_00063636 CONFIDENTIAL — PURSUANT TO FED. R. CRIM. P. 6(e) CONFIDENTIAL DB-SDNY-0026461 EFTA_00I74 I 44 EFTA01298709 Page 3 OFAC RESULTS RDC: 11641989 Not Alerted KC 0198325 The Financial Trust (Global Search) Company FIRCOSOFT: 31721057VVR_317210572182CompanyThe Financial Trust Company No AlertNo AlertNo AlertNo Alert BIS RESULTS: Negative Media: No Information Found Non-Negative Media: PR Newswire October 9.2018 Tuesday 6:30 AM EST IRA Financial Trust Company - Fast Growing Self-Directed IRA Custodian - Announces Average Client Account Fees at I .ess than .001% or Account Value: IRA Financial self-directed IRA flat account fee costs less than the average robo investment advisor fees PR Newswire NEW YORK, Oct. 9.2018 /PRNewswire-PRWeb/ -- IRA Financial Trust Company. the market's fastest growingself- directed IRAcustodian for checkbook IRA and full-service IRA custodian accounts announces that the average self- directed IRA client pays account fees of less than .001% of their IRA account value. With checkbook IRA annual account foes of $180 flat per year and with the average client having around 5200.000 in IRA funds. IRA Financial Trust's self-directed IRA clients are paying less than .001% in account value fees. "We believe that our flat low-cost annual self-directed IRA fee, which averages out to less .001%of the average client's account value is a great value proposition for any robo investor looking to invest in alternative asset investments, such as real estate,' stated Adam Bergman. President of the IRA Financial Trust Company. According to Adam Bergman. a partner with the IRA Financial Group, the costs involved in having a self-directed IRA account has been reduced dramatically allowing retirement account investors to gain more investment options without the increased costs. "The IRA Financial Group has built our businesses on offering low-cost alternative asset self- directed IRA options to retirement account holders whose portfolios may not be big enough for traditional !inns." For Internal use only For internal use only SDNY_Gril_00063637 CONFIDENTIAL - PURSUANT TO FED R.cONE I DENTIAL DB-SDNY-0026462 EFTA_00174145 EFTA01298710 Page 2 IRA Financial Intstis a non-banking IRA Trust company responsible for administeringSelf-Directed IRA custodianaccounts. including checkbook control IRA. to make traditional as well as alternative asset investments, such as real estate. IRA Financial Trust Company was founded by Adam Bergman. a partner with the IRA Financial Group. The IRA Financial Group. the leading provider of self-directed IRA retirement solutions. IRA Financial Group has helped thousands of clients take back control over their retirement funds while gaining the ability to invest in almost any type of investment, including real estate without custodian consent. IRA Financial Group is the market's leading provider of self-directed IRA LLC and Solo 401(k) plans. IRA Financial Group has helped thousands of clients take back control over their retirement funds while gaining the ability to invest in ahnost any type of investment. including real estate without custodian consent. To learn more about the IRA Financial Group please visit our website atlutp://www.irafmancialgronp.comor call 800- 472.0646. To learn more about establishing a self-directed IRA account with the IRA Financial Trust Company please ww.iratinancialtmsiconor call 800-472-1043. SOURCE IRA Financial Group. LLC Copyright 2018 PR Newswire Association LLC All Rights Reserved Other Language Media: Not Required D&B: Copyright 2018 Dun & Bradstreet. Inc Worldbasc November 15, 2015 FINTRASTICOM. OOO t D.25 UL.TSVILLINGA CHELYABINSK 454091 RUSSIAN FEDERATION COUNTY: CHELYABINSKAYA OBL. REGION: EUROPE COMMUNICATIONS TELEPHONE: FAX: COUNTRY CODE: 0007 CABLE TELEX: NNYNNNP COMPANY IDENTIFIERS For Internal use only For internal use only SDNY_GM_00063638 CONFIDENTIAL - PURSUANT TO FED R.cONE I DENTIAL DB-SDNY-0026463 EFTA_00174146 EFTA01298711 Page 2 DUNS: 68-342-9052 NATIONAL: 99249213-Of ice 801 Government Gazette Number COMPANY INFORMATION FOUNDED: 2007 LEGAL STATUS: Corporation EXECUTIVES ***** * * * * • CEO: VYACHESLAV VALEREVICH ZHGUNOV„ PRINCIPAL Download Table DESCRIPTION SECURITY AND COMMODITY EXCHANGES, NSK MARKET AND INDUSTRY PRIMARY SIC: 6231 - Secwity/commodity exchange SECONDARY SIC: 1629 - Heavy construction 1721 - Painting/paper hanging contractor 1742 - Drywall/insulating contractor 1752 - Floor laying contractor 1761 - Roofing/siding contractor FINANCIALS FISCAL YEAR DATE: December 31, 2014 OTHER FINANCIALS FINANCIAL FIGURE DATE 12/31/2014 US DOLLARS Russian Federation Rubles NET WORTH $10,820 - Actual 504.000 - Actual PROFIT $ -751 - Actual 35,000 - Actual Download Table CROSS REFERENCE: • 'FINANCIAL TRUST COMPANY' Public Record: No Information Found LEGAL RESULTS: Court Cases: Beverly Haceesa. Individually. and First Financial Trust Company, as Conservator for Shenoel Haceesa. A Minor. Petitioners v. United States. For Internal use only For internal use only SDNY_GM_00063639 CONFIDENTIAL - PURSUANT TO FED R.CONE I DENTIAL DB-SDNY-0026464 EFTA_00174147 EFTA01298712 No. 02-1640. SUPREME COURT OF THE UNITED STATES 540 U.S. 814; 124 S. O.65; 157 L. Ed. 2d 29; 2003 U.S. LEXIS 5545; 72 U.S.L.W. 3235 October 6. 2003. Decided PRIOR HISTORY: Hacecsa v. United States. 309 F.3d 722, 2002 U.S. App. LEXIS 22192 (10th Cir. NM.. 2002) JUDGES: r 11 Rehnquist, Stevens, O'Connor. Scalia, Kennedy. Sower, Thomas, Ginsburg. Breyer. OPINION Petition for writ of certiorari to the United States Court of Appeals for the Tenth Circuit denied. I of 99 For internal use only For internal use only SONYGM_00063640 CONFIDENTIAL - PURSUANT TO FED R.WNE IDENTIAL DB-SDNY-0026465 EF1'A_00174148 EFTA01298713