Our Commitment to the Prevention of Money Laundering and Terrorist Financing
Lehman Brothers is fully committed to complying globally with all applicable laws designed to combat money laundering and any activity which facilitates the funding of terrorist or criminal activities. The Firm also supports various global efforts and initiatives aimed at preventing money laundering and terrorist financing.

Global Money Laundering Prevention Policies and Procedures
The Firm is committed to educating and training all of its employees in money laundering prevention, and has adopted specific policies and procedures to prevent and detect money laundering and terrorist financing.

As part of its Global Money Laundering Prevention Policy, Lehman Brothers has undertaken the establishment of:

•	A global money laundering prevention program with standards that apply to all Lehman Brothers subsidiaries and employees worldwide;
•	Regional money laundering prevention programs, policies, and procedures that are consistent with the standards set out in the global money laundering prevention program and which address local risks and laws;
•	Designation of global and regional money laundering reporting officers to oversee the implementation and operation of the money laundering prevention program;
•	Global "know your customer" (KYC) standards, including customer identification and verification procedures;
•	Global due diligence and enhanced due diligence procedures for politically exposed persons, foreign banks and other high risk customers, including foreign financial institutions;
•	Development and utilization of technology to assist in the monitoring of transactions for the purpose of identifying and reporting suspicious activity and/or transactions;
•	Procedures for screening clients against applicable sanction programs and lists;
•	Independent audit function to evaluate the Firm's global and regional money laundering prevention programs and policies;
•	Training program for all Lehman Brothers employees to:
	-  become aware of, and comply with, the global and regional policies and procedures to prevent money laundering, terrorist financing and other financial crimes;  -  understand their responsibilities under the regional money laundering prevention program;  -  recognize and report any suspicious activity and/or transactions within their region; and
•	A global anti-bribery and anti-corruption program.