Proprietary Fintrac.RS© FBE Inc., 2001 Slide 1 of 20 FINTRAC Reporting Service (Fintrac.RS) Fintrac.RS Client Government

Proprietary Fintrac.RS© FBE Inc., 2001 Slide 2 of 20 FINTRAC Compliance and Reporting Requirements zProceeds of Crime (Money Laundering) Act received Royal Assent on June 29, 2000 yLegislates detection and deterrence of money laundering yAll Canadian deposit-taking institutions are subject to the Act, Regulations and Guidelines ySuspicious transactions reporting starts 2001-Nov-08 zRequires: yImmediately report to FINTRAC all suspicious transactions yPeriodically report and keep the prescribed records

Proprietary Fintrac.RS© FBE Inc., 2001 Slide 3 of 20 FINTRAC Enforcement zFailure to implement a compliance regime: yConviction up to 5 years + $500,000 fine zFailure to report a suspicious transaction could lead to substantial fines and legal actions yConviction up to 5 years + $2,000,000 fine yNo minimum threshold for reporting zRequired maintain effective record-keeping system (penalty: up to 5 years imprisonment and $500,000) zFINTRAC and external auditors should have access to all the records in a timely fashion

Proprietary Fintrac.RS© FBE Inc., 2001 Slide 4 of 20 FINTRAC Enforcement (con’s) zEmployees who reported to their superior are exempted from being charged under the Act!!! yThe ultimate executive responsibility yNeed to document to discharge responsibility, archiving is crucial yFor electronic records, an electronic signature of the signing individual “must be retained” zA special Individual Responsible for implementing FINTRAC Compliance must be appointed yTypically reports to the CEO or the Board

Proprietary Fintrac.RS© FBE Inc., 2001 Slide 5 of 20 Focus on Service Success! zNo paper pushing, easy to use, no training is required zRapid approval cycle zEnhanced control, reporting and audit trail zEffectively manages executive participation; Line management and executives are fully in control zReduces transaction cost of backroom administrative cycle from $54 to $8 zSubstantial saving in development, maintenance and upgrades

Proprietary Fintrac.RS© FBE Inc., 2001 Slide 6 of 20 FINTRAC Processes/Forms Integrated zSuspicious/Prescribed Transaction Report yTransaction type:Account transaction; Conducted for another entity Conducted for other individual(s) yLarge case transactions yExceptions to large cash transactions yElectronic funds transfers yCross-border transactions to CCRA zFINTRAC Schedules (as introduced) y1. Suspicious Transaction Report y2. Large Cash Transaction Report y3. Outgoing Electronic Funds Transfer Report Information y4. Incoming Electronic Funds Transfer Report Information

Proprietary Fintrac.RS© FBE Inc., 2001 Slide 7 of 20 A New Level of Accountability zEnsures compliance with all respective government and corporate policies zAdditional Processes/Forms Integrated yFintrac.RS Executive Reports yCumulative Reporting (for all participants) yMaintains User Profile and reporting relations yTracking Inquiries/Requests Archives yTransaction Logs yService Quality Evaluations zAlso FINTRAC compliance training and support

Proprietary Fintrac.RS© FBE Inc., 2001 Slide 8 of 20 Fintrac.RS Step-by-Step 1) Suspicious/prescribed transaction report request with required identity data (without disclosing it to the Client) yVery complex forms with dozens of input fields are required to fill for every transaction 2) Request approval by corporate management 3) Automatic FINTRAC compliance clearance 4) Transaction reporting within Fintrac.RS 5) Periodic corporate reporting to FINTRAC 6) Reporting to CCRA on the import/export of currency 7) Prescribed effective, safe and secure record keeping 8) Internal and external auditing yWe also implemented numerous interactive enablers that add value to users and lower overall service costs

Proprietary Fintrac.RS© FBE Inc., 2001 Slide 9 of 20 Fintrac.RS: (Un)Cooperating Users FINTRAC Supervisor Internal/External Auditors Fintrac Schedules (4) Fintrac.RS Suspicious/ prescribed Transaction Report Compliance officer CEO CCRA Cross-border transactions Police Teller ?? Client(s) ? ? PKI

Proprietary Fintrac.RS© FBE Inc., 2001 Slide 10 of 20 Business Platform zManagement framework yIntegrated Government and corporate policies and expertise - on a transactional level yCentral reporting zBuilt in user preferences/Feedback yException Management yService Quality Evaluations — user feedback for every transaction yArchives, Transaction Logs

Proprietary Fintrac.RS© FBE Inc., 2001 Slide 11 of 20 Business Platform (con’s) zEnhanced inherently secure processes yintranet solution — same security level as for all other legacy applications yReporting relationships built in y approval notification/confirmations for every business cycle yPrescribed by Regulations safe and secure keeping of the records yPeriodic PKI submission of cumulative records to the Government (batch file reporting starts Jan 2002).

Proprietary Fintrac.RS© FBE Inc., 2001 Slide 12 of 20 Software Platform zAlmost 1,000,000 lines of code — and growing... zUbiquitous yW2k yPerl y.asp yPage style templates yFull compliance with Federal Government IT platform requirements zSMTP-compatible mail server yCompliant with STD0010 yRFC821, RFC1651, RFC1869, RFC1870

Proprietary Fintrac.RS© FBE Inc., 2001 Slide 13 of 20 Software Platform (con's) zXML yxHTML yBackward compatible with older browsers yPotential for structuring every field yI.e., transparent interface with financial, HR, etc. legacy systems zSQL engine yMS Access yImplemented as ODBC/SQL compliant database yUpgradable to Oracle

Proprietary Fintrac.RS© FBE Inc., 2001 Slide 14 of 20 Software Platform (con's) zNo installation on a desktop yAny browser yAny client zRich, fully interactive Web site yMailing list yStats, Search engine, Guestbook, etc., etc zWorkflow engine zPolicy shell yAI smarts if required to deliver policy yFull expert system shell can be built in

Proprietary Fintrac.RS© FBE Inc., 2001 Slide 15 of 20 Software Platform (con's) zSmart forms yAlways change in context, workflow defined yLittle writing in yInput field integrity checking, precise error messages yIntegrated window warnings and password requests yPrecise label links to the help file (Help in context) yDisplays only relevant input/output fields yAlways Web page acknowledgement at the end y acknowledgements after update sent to the originator and recipients in context y notifications in advance (i.e., to request updates)

Proprietary Fintrac.RS© FBE Inc., 2001 Slide 16 of 20 System Architecture CCRA Fintrac.RS Server Internet Corporate users Fintrac Audit Trail databases Client and Transaction databases Fintrac.RS Administrator (Setup/modify corporate clients, authorizations and policy)

Proprietary Fintrac.RS© FBE Inc., 2001 Slide 17 of 20 Advantages zStreamlines and expedites: yInternal suspicious transaction reporting yAuthorization processes zPreserves interests of front-line workers, executives and clients yAvoiding false positives and false negatives yReporting transactions are completed only after responsible managers authorize them yGovernment/corporate suspicious transaction reporting cycle guidelines and approval procedures available online to guarantee there are no misunderstandings of organization's policy

Proprietary Fintrac.RS© FBE Inc., 2001 Slide 18 of 20 Advantages (con's) zEnhanced controls yIdentifying exceptions yCountrywide and worldwide reach ySecure zSavings yNo LAN installation yLow cost per online transactions and maintenance yVery fast payback zCustomizable yAddresses your organization’s unique requirements yERP off-ramps

Proprietary Fintrac.RS© FBE Inc., 2001 Slide 19 of 20 Future Customization Options zBanking Systems yOptional customization modules for direct access to Banking Systems zHR Systems yModules for direct access to HR Systems yi.e., reporting relationships zFinancial Systems yModules for direct access to Financial Systems ye.g. SAP, Oracle, ACCPAC zComprehensive Reporting

Proprietary Fintrac.RS© FBE Inc., 2001 Slide 20 of 20 FINTRAC Reporting Service (Fintrac.RS) Fintrac.RS Client Government