To be in business EP Capital as financial institution is subject to the following regulatory requirements:

• Registered with FinCEN (Updates every 2 years).
• Back Secretary Act (must comply with reporting and record keeping)
• USA Patriot Act (must have independent audit, designated Compliance Officer, polices and procedures, employee and agent training program).
• OFAC (sanctioned countries and SDN list screening).
• Gramm-Leach-Bliley Act (Consumer Privacy).
• Authorized Delegates/Agents (current list readily available for regulators.

High Compliance Standards

EP Capital will operate with select customers under the following premises and controls:

• Customer must be in business for at least two years and be in good standing.
• Customer must provide updated documentation, including most recent copy of audited financial statements.
• Customer must have a Risk Score of Moderate or Low-Risk Scores based on controls and other criteria implemented by the Customer.
• Delivery of the currency purchased must be made to the customer’s or supplier’s account with its correspondent bank in the destination country.
• Payment of the purchased currency must be received by EP Capital prior to delivery of foreign currency. WIRE TRANSFERS ONLY (no cash or checks).
• Consumer Privacy Policy

General Description

• EP Capital is committed to providing consumers with the finest financial products and services backed by consistent high-quality service and to protecting the privacy and confidentiality of non-public consumer information from unlawful use and disclosure.
• Maintaining the trust and confidence of consumer is a high priority to the Company.
• Accordingly, EP Capital has developed guidelines to protect consumers’ privacy and confidentiality and to communicate its commitment to consumers to better serve their privacy needs.
• EP Capital does not sell or share non-public personal information about consumers with third parties except on a limited basis as detailed in this Policy and in the related Procedures and as required by law.
• To inform consumers about the EP Capital Policy and EP Capital commitment to their privacy and confidentiality needs, the Company will provide consumers with the privacy policy disclosure statement.
• EP Capital reserves the right to change its privacy policy at any time. If the policy is changed, consumers will be informed to the changes on a timely manner. Note: All references to EP Capital.