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Anti-Money Laundering Program top
Summary of Anti-Money Laundering (AML) Related Information

Company Status with Regulators

Mizuho Securities USA Inc. (“MSUSA”) is a registered broker and dealer with the U.S. Securities and Exchange Commission and a member of the securities self-regulatory organization, the National Association of Securities Dealers. MSUSA also is registered as a futures commission merchant with the U.S. Commodity Futures Trading Commission and a member of the futures self-regulatory organization, the National Futures Association. As such, MSUSA is considered a “covered financial institution” for purposes of the U.S. Bank Secrecy Act and is subject to its regulations as well as the rules and oversight of the federal regulatory authorities and self-regulatory organizations listed above.

Anti-Money Laundering Program

It is the policy of MSUSA to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets. MSUSAs Anti-Money Laundering Program has been designed to comply with legal and regulatory requirements, including NASD Rule 3011 and NFA Compliance Rule 2-9, by:

(a) including procedures that can be reasonably expected to detect and cause the reporting of transactions required under 31 U.S.C. 5318(g) and the implementing regulations thereunder;

(b) including policies, procedures, and internal controls reasonably designed to achieve compliance with the Bank Secrecy Act and the implementing regulations thereunder;

(c) providing for independent testing for compliance to be conducted by appropriate staff or by a qualified outside party;

(d) designating individuals responsible for implementing and monitoring the day-to-day operation and internal controls of the Anti-Money Laundering Program; and,

(e) providing for ongoing training of appropriate staff.

Customer Identification Program

In compliance with federal anti-money laundering requirements, MSUSA has developed and implemented a Customer Identification Program (“CIP”) to identify and verify the identity of customers that open new accounts. The purpose of the CIP process is to ensure that MSUSA has taken reasonable efforts to determine the identity of its customers through documentary and or non-documentary means.

Notice to Prospective Customers

To help the U.S. government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person or entity who opens an account. When you open an account, we are required to ask for certain identifying information such as your name, address, and other information that will allow us to identify you. We also may ask to see identifying documents to verify your identity and to screen your name against various government databases.

Notice Regarding Entities Identified As Being of Primary Money Laundering Concern

Pursuant to U.S. regulations issued under section 311 of the USA PATRIOT Act, 31 CFR 103.192, we are prohibited from opening or maintaining a correspondent account for, or on behalf of, the Specified Banks, see list below. The regulations also require us to notify you that your correspondent account (if applicable) with our financial institution may not be used to provide the Specified Banks with access to our financial institution. If we become aware that the Specified Banks are indirectly using the correspondent account (if applicable) you hold at our financial institution, we will be required to take appropriate steps to prevent such access, including terminating your account.

Specified Banks

Banco Delta Asia SARL of Macau, China and its subsidiaries, including:
·   Delta Asia Credit Limited
·   Delta Asia Insurance Limited

Burma, including:
·   Asia Wealth Bank
·   Myanmar Mayflower Bank

Commercial Bank of Syria and its subsidiaries, including:
·   Syrian Lebanese Commercial Bank

VEF Banka of Latvia and its subsidiaries, including:
·   Veiksmes lízings

Questions

Any questions regarding MSUSAs Anti-Money Laundering Program, Customer Identification Program or requests to share information under Section 314(b) of the USA PATRIOT Act should be directed to:

Richard Lembach
AML Compliance Officer
Mizuho Securities USA Inc.
1251 Avenue of the Americas, 33rd Floor
New York, NY 10020
212-209-9462 telephone
917-512-7173 facsimile


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