Swiss Bank Independent Examiner

(SWISS BANK) INDEPENDENT EXAMINER

GENEVA | HONG KONG | SEATTLE | SHANGHAI

and Summary of the “Program for Non-Prosecution Agreements or Non-Target letters for Swiss Banks” as announced on August 29, 2013 by the U.S. Department of Justice and the Swiss Federal Department of

Finance

International

Accounting &

Compliance

International Accounting & Compliance

IMPORTANT LEGAL INFORMATION PLEASE READ

LEGAL NOTICE This presentation is prepared for general guidance only, and does not constitute the provision of accounting, legal or tax advice in any manner, written tax advice under U.S. Internal Revenue Service Circular 230, or any professional advice of any kind. “Gray International” or “Gray” refers to Gray CPA, PC (a U.S. CertiIied Public Accounting Iirm) and Gray International Ltd (a Hong Kong Limited Company). The information provided in this presentation should not be a substitute for consultation with qualiIied professionals who understand your situation, as it will differ from others. In addition, when making any tax planning or legal decisions you should consult with your own legal, tax, accounting and other professional advisors. This presentation has been provided as a courtesy, and therefore while care has been executed in the preparation of this information Gray CPA, PC (U.S.), Gray International, Ltd. and all of their afIiliates make no representations as to its completeness, accuracy or the timeliness of the information and takes no responsibility to update this information, such information is being provided without warranty of any kind. The U.S. Department of Justice and the Swiss Federal Department of Finance has not reviewed this document, does not endorse or in any other manner render an opinion on the merits of Gray’s offering of independent examiner services, and any representation to the contrary is unlawful. For more information about us, please visit us at www.grayintl.com. © 2013 Gray CPA, PC and Gray International Ltd. with all rights reserved, this document shall not be reproduced or distributed without the express written permission of Gray CPA, PC and Gray International, Ltd.

WWW.COMPANYSITE.COM | [email protected] | +123 456 789 | THIS STREET 321, CITY, COUNTRY


WHO WE ARE OUR PROFILE

Gray International (“Gray”) is an international network of public accounting and consulting Iirms based in the U.S., Hong Kong, China and Europe. Gray was started over 10 years ago in the U.S. (via its predecessor) and took the form of Gray International in 2013 as the result of the networking of multiple independent practices and professionals. Gray provides international accounting and compliance solutions in the U.S., Americas, Asia and Europe. Gray focuses on U.S. accounting, tax, and governmental compliance for multinational companies,

investors, U.S. persons living overseas and foreign investors and companies investing in or moving to the U.S. Gray also consults on compliance with U.S. laws for businesses and Iinancial institutions overseas such as the Foreign Corrupt Practices Act (FCPA) and the Foreign Account Tax Compliance Act (FATCA), the IRS Offshore Voluntary Disclosure Program, and the Program for Non-‐Prosecution Agreements or Non-‐Target letters for Swiss Banks. Gray’s principals, partners, and employees have served

clients worldwide. Gray has ofIices in Geneva, Hong Kong, Seattle, Shanghai and plans to open an ofIice in Singapore in late 2013. Gray’s U.S. public accounting Iirm (Gray CPA, PC) is registered with the U.S. Public Company Accounting Oversight Board and is a member of the American Institute of CertiIied Public Accountants and the Center for Audit Quality. For more information about us, please visit us at: www.grayintl.com


OUR SERVICES

WHAT WE DO

AUDIT AND ATTEST SERVICES

INTL. FORENSIC ACCOUNTING

U.S. TAX COMPLIANCE

U.S. FATCA COMPLIANCE

INTL. TAX STRUCTURING

U.S. FCPA COMPLIANCE


WHAT WE DO OUR PRACTICE AREAS

U.S. FCPA COMPLIANCE

AUDIT AND ATTEST SERVICES INTL. FORENSIC ACCOUNTING

No single piece of U.S. legislation will have a larger impact on foreign Iinancial institutions and intermediaries in the next 5 years as FATCA. Let us help you assess how this will impact your organization and how to implement a practical, affordable solution.

In today’s global landscape international tax structuring and planning has never been more important. From transfer pricing, treaty compliance, withholding minimization, estate planning and domiciliation, to pre-‐residency tax planning Gray is ready to help you navigate this difIicult terrain.

Widespread globalization brings increased risks of corrupt practices, and correspondingly, an increase in FCPA enforcement, penalties and prosecutions. Let Gray help you prepare and implement appropriate controls to protect your organization from violations.

Our experienced auditors provide extensive experience auditing public and private companies in the developed and developing markets. Let us put our extensive experience operating in the U.S., Asia, Europe and the Americas to work for you.

Our forensic accounting services are designed to providing vigilance before the fact, reconstructing and tracing records after the fact, and preparing for trial once the Iindings are made. Our team of experts are available for worldwide engagement.

Gray provides extensive U.S. tax compliance solutions to clients worldwide. We work with individuals, family ofIices, investors, Iinancial institutions, multinational companies and domestic (U.S.) businesses. Let us guide you through the maze of complex U.S. tax compliance.

U.S. TAX COMPLIANCE

U.S. FATCA COMPLIANCE INTL. TAX STRUCTURING


GEOGRAPHIC AREAS OF EXPERIENCE

WHERE WE WORK

WWW.COMPANYSITE.COM | [email protected] | +123 456 789 | THIS STREET 321, CITY, COUNTRY R. Congo

Zambia

Yemen

Westsahara

Vietnam

Venezuela

U.A.E

Uzbekistan

USA

Uruguay

Ukraine

Uganda

Chad

Tunisia

Turkey Turkmenistan

Togo

Thailand

Tanzania

Taiwan

Tajikistan Syria

Swaziland

South Korea

South Africa

Spain

Zimbabwe

Suriname

Sudan

Somalia Sierra Leone

Senegal

Sweden

Saudi Arabia

Russia

Romania

Portugal

Poland

Philippines

Peru

Paraguay

Papua New Guinea

Panama

Pakistan

Oman

Norway

North Korea

Nikaragua Nigeria

Niger

New Zealand

Nepal

Namibia

Myanmar

Mozambique

Mongolia

Morocco

Mexico

Mauritania Mali

Malaysia

Madagascar

Libya

Liberia

Lebanon

Lesotho

Laos

Kyrgysistan

Kenya

Qatar

Kazazhstan

Cambodia

Japan

Jamaica

Israel

Italy

Ireland

Iraq Iran

Indonesia

India

Iceland

Honduras

Guyana Guinea

Guatemala

Greenland

Greece

Great Britain

Ghana

Germany

Gabun Fr. Guyana

France

Finland

Ethiopia

Eritrea

El Salvador

Egypt

Ecuador D. R. Congo

Dom. Rep. Cuba

Columbia

Cote d‘Ivoire

Costa Rica

China

Chile

C.A.R.

Canada

Kamerun

Burkina

Brazil

Botswana

Bolivia

Bhutan

Belize

Belarus

Bangladesh

Bahamas

Australia

Argenena

Angola

Algeria

Alaska

Afghanistan


SWITZERLAND Gray has extensive experience working in Switzerland. The Firm has represented both Swiss companies and individuals, as well as U.S. taxpayers who have sough relief under the U.S. Offshore Voluntary Disclosure Program (OVDP). The Firm launched its (Swiss Bank) Independent Examiner services in response to the release of the Program For Non-‐Prosecution Agreements or Non-‐Target Letters for Swiss Banks, by and between the U.S. Department of Justice and Swiss Federal Department of Finance, on August 29, 2013. The Firm has a depth of relationships in Switzerland, and has extensive experience operating under both Swiss law and in compliance with U.S. laws and regulations (both tax and securities). The Firm is committed to Switzerland, and as a result Switzerland is one of our key markets. The Firm focuses on the following key practice areas in Switzerland:


OFFSHORE VOLUNTARY DISCLOSURES PFIC REPORTING/COMPLIANCE

U.S. TAX OPINIONS

FATCA IMPLEMENTATIONS (SWISS BANK) INDEPENDENT EXAMINER


THE U.S. DOJ / SWISS PROGRAM


AN OVERVIEW


THE PROGRAM

The “Program for Non-‐Prosecution Agreements or Non-‐Target Letters for Swiss Banks” as announced jointly by the United States Department of Justice (the “DOJ”) and the Swiss Federal Department of Finance on August 29, 2013 ( “the Program”) is open to every Swiss Bank that is not currently under investigation by the DOJ (further deIined as Category 1 Banks). The Program provides a mechanism for banks to resolve past U.S. cross-‐border regulatory exposure, deIine their potential exposure, and mitigate penalties (if their U.S. account holders duly disclose the existence of the account(s) under an Offshore Voluntary Disclosure after the bank has notiIied the client of such program). Compliance with the Program should result in the avoidance of prosecution by the DOJ. The key features of the program are as follows:

•  Category 1 Banks (the 14 banks that are already under investigation by the DOJ) are not eligible to participate in the program.

•  Category 2 Banks will pay a penalty and may request a Non-‐Prosecution Agreement (“NPA”) from the DOJ.

•  Category 3 and 4 Banks will be able to prove compliance with U.S. laws (i.e. prove their

innocence) and will obtain a Non-‐Target Letter (“NTL”) from the DOJ and will not pay penalties.

•  Mutual undertaking: The Program is mutual understanding between the Swiss and U.S. Government, the Swiss State Secretariat for International Financial Matters (“SIF”) has released a Circular Letter on July 3, 213 which outlines the terms under which Swiss Banks are allowed to co-‐operate in the Program.



CATEGORY 2 BANK A Category 2 Bank is any Swiss bank:

•  As to which the DOJ has not authorized a formal criminal investigation concerning its operations as of August 29, 2013 (i.e. that is not a Category 1 Bank);

•  that is not a Category 4 Bank; and

•  that has reason to believe it may have committed tax-‐related offenses under Titles 18 or 26, United States Code, or monetary transactions offenses under § § 5314 or 5322, Title 31, United States Code, in connection with undeclared U.S. Related Accounts held by the Swiss Bank during the Applicable Period;

•  which may request a Non-‐Prosecution Agreement on the terms set out in the Program.





•  that is not a Category 4 Bank; and

•  that not committed any tax-‐related offenses under Titles 18 or 26, United States Code, or monetary transactions offenses under § § 5314 or 5322, Title 31, United States Code, in connection with undeclared U.S. Related Accounts held by the Swiss Bank during the Applicable Period (i.e. that is not a Category 2 Bank);

•  may request a Non-‐Target Letter on the terms set out in the Program.





•  that is “Deemed Compliant Financial Institution” as a “Financial Institution with Local Client Base” under the FATCA Agreement, Annex II Paragraph II.A.1, as if the FATCA Agreement were in force during the Applicable Period (except that the Swiss Bank must meet the terms of Annex II, Paragraph II.A.1.e on December 31, 2009, and the date of the announcement of this Program);

•  may request a Non-‐Target Letter on the terms set out in the Program.



THE PROGRAM – CATEGORY 2 BANKS



REQUESTING THE NPA

Each Swiss Bank requesting an NPA must provide a letter to the DOJ (Tax Division), expressing its intent, no later than December 31, 2013. The letter must:

•  Include a plan for complying with the requirements set forth in the Program, within a reasonable time, but not to exceed 120 days from the date of the letter of intent;

•  provide the identity and qualiIications of the Independent Examiner;

•  state that the Swiss Bank will maintain all records required for compliance with the terms of an NPA as set out in the Program, including all records that may be sought by treaty requests; and

•  state that the Swiss Bank agrees that with respect to any applicable statue of limitations that has not expired as of the date of the announcement of this Program, the Bank waives any potential defense based on the statute of limitations for the period from the date of the announcement of the Program to the issuance of an NPA or a DPA (deferred prosecution agreement).

•  Note: If the Bank is not able to comply with the requirements set out in the Program within 120 days from the date of the letter of intent, the DOJ will grant a one-‐time extension of 60 days upon a showing of good cause.

•  If the DOJ concludes that a Swiss Bank has met all obligations set forth in the NPA, the Department will not prosecute the Swiss Bank for any tax-‐related offenses under Titles 18 or 26, United States Code, or for any unreported monetary transactions under §§ 5314 or 5322, Title 31, United States Code, in connection with undeclared U.S. Related Accounts held by the Swiss Bank during the Applicable Period.



SUBMISSION OF EVIDENCE AND INFORMATION (PRIOR TO THE NPA)

Each Swiss Bank requesting an NPA must fully cooperate in the disclosure of the following evidence and information prior to the execution of an NPA :

•  How the cross-‐border business for U.S. Related Accounts was structured, operated, and supervised (including internal reporting and other communications with and among management);

•  the name and function of the individuals who structured, operated, or supervised the cross-‐border business for U.S. Related Accounts during the Applicable Period;

•  how the Swiss Bank attracted and serviced account holders;

•  an in-‐person presentation and documentation, property translated, supporting the disclosure of the above information, as well as cooperation and assistance with further explanation of information and materials so presented, upon request, or production of additional explanatory materials as needed; and

•  The total number of U.S. Related Accounts and the maximum dollar value, in the aggregate, of the U.S. Related Accounts that:

•  existed on August 1, 2008 •  were opened between August 1, 2008, and February 28, 2009; and •  were opened after February 28, 2009



SUBMISSION OF EVIDENCE AND INFORMATION (UPON EXECUTION OF THE NPA)

Upon execution of an NPA, for all U.S. Related Accounts that were closed during the Applicable Period, the Swiss Bank must provide information including:

•  The total number of accounts; and

•  as to each account:

•  The maximum value, in dollars, or each account, during the Applicable Period; •  the number of U.S. persons or entities afIiliated or potentially afIiliated with each account, and further noting the nature of the relationship to the account of each such U.S. person or entity or potential U.S. person or entity;

•  whether it was held in the name of an individual or an entity;

•  whether it held U.S. securities at any time during the Applicable Period;

•  the name and function of any relationship manager, client advisor, asset manager, Iinancial advisor, trustee, Iiduciary, nominee, attorney, accountant, or other individual or entity functioning in a similar capacity known by the Bank to be afIiliated with said account at any time during the Applicable Period; and

•  information concerning the transfer of funds into and out of the account during the Applicable Period on a monthly basis (including, but not limited to, cash transfers, transfers though intermediaries, and identiIication of transferring or transferee Iinancial institutions)



NPA - PENALTY STRUCTURE

Upon execution of an NPA, the Swiss Bank will agree to pay as a penalty:

•  For U.S. Related Accounts that existed on August 1, 2007, an amount equal to 20% of the maximum aggregate dollar value of all such accounts during the Applicable Period;

•  for U.S. Related Accounts that were opened between August 1, 2008, and February 28, 2009, an amount equal to 30% of the maximum aggregate dollar value of all such accounts; and

•  for U.S. Related Accounts that were opened after February 28, 2009, an amount equal to 50% of the maximum aggregate value of all such accounts.

•  Penalty Mitigation Provision: The determination of the maximum dollar value of the aggregated U.S. Related Accounts may be reduced by the dollar value of each account as to which the Swiss bank demonstrates, to the satisfaction of the DOJ, was not an undeclared account, was disclosed by the Swiss Bank to the U.S. IRS, or was disclosed to the U.S. IRS through an announced Offshore Voluntary Disclosure Program or Initiative following notiIication by the Swiss Bank of such a program or initiative and prior to the execution of the NPA.



CLOSURE OF ACCOUNTS AND POST NPA COMPLIANCE

Closure of Accounts: The terms of an NPA will provide that the Swiss Bank agrees to close any and all accounts of recalcitrant account holders, as deIined in Section 1471(d)(6) of the U.S. Internal Revenue Code (i.e. all undeclared accounts). The Terms of the NPA will require that the Swiss Bank implement procedures to prevent its employees from assisting recalcitrant account holders to engage in acts of further concealment in connection with closing any account or transferring any funds. Will not open undeclared accounts: The terms of the NPA will also provide that the Swiss Bank agrees not to open any U.S. Related Accounts except on conditions that ensure that the account will be declared to the U.S. and will be subject to disclosure by the Swiss bank. Testimony and Treaty Requests: In addition the Swiss Bank, upon request, will provide that for the testimony of a competent witness or information as needed to enable the DOJ to use the information and evidence obtained pursuant to the provisions on the Program or separate treaty request in any criminal or other proceeding; and will assist in the identiIication and translation of signiIicant documents at the expense of the Swiss Bank. Records: In furtherance of these provisions, the Swiss Bank will maintain all records related to its U.S. cross-‐border business for a period of 10 years from the termination date of the NPA.



INDEPENDENT EXAMINER’S REPORT (NPA)

Prior to the execution of the NPA, the Swiss Bank will, at its expense, have the information as submitted to the DOJ, veriIied by an Independent Examiner. The veriIication will include a statement that the Independent Examiner has conIirmed that the due diligence standards set forth in the Program, were applied in collecting the information. The Independent Examiner’s report must be sent to the DOJ (Tax Division) for review.



FALSE OR MISLEADING INFORMATION

If the DOJ determines (in its sole discretion) that any information or evidence provided by the Swiss Bank is materially false, incomplete, or misleading, it may decline to enter into an NPA. If after entering the NPA, the DOJ determines that the Swiss Bank has provided materially false, incomplete or misleading information or evidence, or has otherwise materially violated the terms of the NPA, the U.S. may pursue any and all legal remedies available to it, including investigating and instituting criminal charges against the Swiss Bank, without regard to any other provision of the NPA or the Program.






REQUESTING THE NTL (CATEGORY 3 BANKS)

Each Swiss Bank requesting an NTL must provide a letter to the DOJ (Tax Division), expressing its intent, no earlier than July 1, 2014 and no later than October 31, 2014. The letter must:



•  state that the Swiss Bank will maintain all records required for compliance with the Program;

•  state that the Swiss Bank agrees that with respect to any applicable statue of limitations that has not expired as of the date of the announcement of this Program, the Bank waives any potential defense based on the statute of limitations for the period from the date of the announcement of the Program to the issuance of a Non-‐Target Letter.



INTERNAL INVESTIGATION (CATEGORY 3 BANKS)

A Swiss Bank requesting a NTL must at its own expense, engage and Independent Examiner to conduct an independent internal investigation. At the conclusion of the internal investigation the, Swiss Bank and the Independent Examiner must:

•  Verify the percent of the Swiss Bank’s account holdings and asset under management that are U.S. Related Accounts;

•  verify that the Swiss Bank has an effective compliance program, accompanied by a description of the compliance program; and

•  provide the DOJ with a report of the Independent Examiner’s internal investigation, prepared in English, that includes: (i) a list of the witnesses, including titles, interviewed by the Independent Examiner and a summary of the information provided by each witness; (ii) identiIication of the Iiles reviewed by the Independent Examiner; (iii) the factual Iindings of the Independent Examiner; and (iv) the conclusions reached by the Independent Examiner.



CLOSURE OF ACCOUNTS AND POST NTL COMPLIANCE

Closure of Accounts: The Swiss Bank requesting the NTL must agree to close any and all accounts of recalcitrant account holders, as deIined in Section 1471(d)(6) of the U.S. Internal Revenue Code (i.e. all undeclared accounts) and shall implement procedures to prevent its employees from assisting recalcitrant account holders to engage in acts of further concealment in connection with closing any account or transferring any funds. Will not open undeclared accounts: The Swiss Bank shall also agree not to open any U.S. Related Accounts except on conditions that ensure that the account will be declared to the U.S. and will be subject to disclosure by the Swiss bank. Records: The Swiss bank shall maintain all notes, drafts, correspondence, reports, and other documents or records created or prepared in any manner by the Independent Examiner, or reviewed by or provided to the Independent Examiner, for a period of ten years from the date of the Non-‐Target Letter. False or Misleading Information: If the DOJ determines (in its sole discretion) that any information or evidence provided by the Swiss Bank is materially false, incomplete, or misleading, or Iinds that it has otherwise materially violated the terms of any agreement with the U.S., the U.S. may pursue any and all legal remedies available to it, including investigating and instituting criminal charges against the Swiss Bank, without regard to any other provision of the NTL or the Program.



CHANGE FROM CATEGORY 3 TO CATEGORY 2

If a Swiss Bank, after having undertaken an investigation in a timely and good faith manner, belatedly determines, based on the discovery of information that in good faith could not have been discovered previously, that it should instead have requested an NPA as a Category 2 Bank, the DOJ may consider whether to enter into discussions with the Swiss Bank as if the Swiss Bank had timely requested an NPA under the terms of the Program. A request for relief under this provision must be made before October 31, 2014. Relief will be granted at the sole discretion of the DOJ, and only under extraordinary circumstances. Under no circumstances will such relief be considered if the DOJ has authorized a formal criminal investigation concerning the operations of the Swiss bank, or has received information concerning wrongful conduct by the Swiss Bank.






REQUESTING THE NTL (CATEGORY 4 BANKS)

Each Swiss Bank requesting an NTL as a Category 4 Bank must provide a letter to the DOJ (Tax Division), expressing its intent, no earlier than July 1, 2014 and no later than October 31, 2014. The letter must:



•  state that the Swiss Bank will maintain all records required for compliance with the the Program;

•  state that the Swiss Bank agrees that with respect to any applicable statue of limitations that has not expired as of the date of the announcement of this Program, the Bank waives any potential defense based on the statute of limitations for the period from the date of the announcement of the Program to the issuance of a Non-‐Target Letter.



INTERNAL INVESTIGATION AND EVIDENCE (CATEGORY 4 BANKS)

To obtain a NTL as a Category 4 Bank, a Swiss bank must:

•  Provide veriIication executed by the Swiss Bank and an Independent Examiner that:

i.  It is not currently the target of an authorized formal criminal investigation concerning its operations by the DOJ, that it is a “Deemed Compliant Financial Institution” as a “Financial Institution with Local Client Base” under the FATCA Agreement;

ii.  agree to maintain records sufIicient to establish the basis for veriIication of its

status as a Category 4 Bank for a period of ten years from the date of the Non-‐Target Letter; and

iii.  agrees that, if the DOJ determines (in its sole discretion), determines that any

information or evidence provided by the Swiss Bank is materially false, incomplete, or misleading, or Iinds that it has otherwise materially violated the terms of any agreement with the U.S., the U.S. may pursue any and all legal remedies available to it, including investigating and instituting criminal charges against the Swiss Bank, without regard to any other provision of the NTL or the Program.



OTHER PROVISIONS (ALL BANKS)

•  The DOJ will not authorize formal criminal investigation of any additional Swiss banks in connection with undeclared U.S. Related Accounts held by the Swiss bank during the Applicable Period before January 1, 2014.

•  The personal data provided by the Swiss banks under this Program will be used and disclosed only for purposes of law enforcement (which may include regulatory action) in the U.S. or as otherwise permitted by U.S. law.

•  The Program is conditioned on the intention of Switzerland, as stated in the Joint Statement between the U.S. Department of Justice and the Swiss Federal Department of Finance dated August 29, 2013, to encourage Swiss Banks to consider participation in the Program. Should Switzerland fail to provide or act to withdraw such encouragement, or should legal barriers prevent effective participation by the Swiss Banks on the terms set out in the Program, the Program may be terminated.



(SWISS BANK) INDEPENDENT EXAMINER


OUR SERVICES


INDEPENDENT EXAMINER SERVICES

Gray International (via: Gray CPA, PC – a U.S. CertiIied Public Accountant) is uniquely positioned to provide full scale Independent Examiner Services in Switzerland and can handle the “short notice” demands of the Program for all levels of Swiss Banks. Gray is authorized to practice in front of the U.S. Internal Revenue Service, and is PCAOB registered which means that it is authorized to act as an auditor for companies registered with the U.S. Securities and Exchange Commission. Gray is a member of the American Institute of CertiIied Public Accountants and the Center for Audit Quality (U.S.). Gray has a breadth of experience in international auditing, compliance, U.S. Taxation, U.S. Offshore Voluntary Disclosures, and operating in the Swiss environment.


FULL SCALE INDEPENDENT EXAMINER

U.S. CPA(s)

EXTENSIVE SWISS EXPERIENCE

U.S. TAX ATTORNEYS

U.S. SEC AUDITORS


LEAD EXAMINER

Mr. Stobie is the CEO of Gray International, Ltd (and Gray CPA, PC), with over 10 years experience practicing as a certiIied public accountant and subject matter expert (consulting and testifying). Mr. Stobie specializes in international taxation, accounting and auditing, anti-‐money laundering and corruption. Mr. Stobie has represented clients from Mexico, China, Malaysia, Hong Kong, Taiwan, Singapore, Iran, Ghana, the Ivory Coast, Pakistan, the United Arab Emirates, Columbia, Canada, Ukraine, Switzerland, France, Luxembourg and many other countries. Mr. Stobie has over 13 years experience in Iinance, securities and private equity and also serves as the Chief Executive OfIicer and Chief Compliance OfIicer of Capital Privé Suisse S.A. (registered with the U.S. SEC and a member in good standing with the Association Romande de Intermédiaries Financiers) a Geneva based fund sponsor and private wealth manager. Mr. Stobie has served as Chief Financial ofIicer, Chief Executive OfIicer and Managing Partner for a myriad of domestic and international businesses over the last decade. Mr. Stobie has extensive experience operating and investing in both developing and developed markets. Mr. Stobie has experience in M&A Advisory, SEC Practice and Reporting, Securities Compliance, Venture Capital, Mezzanine Financing, Forensic Accounting and United States Tax. Mr. Stobie is a CertiIied Public Accountant (State of Texas and State of Washington), CertiIied Fraud Examiner, Chartered Global Management Accountant, and CertiIied in Financial Forensics by the American Institute of Public Accountants. Mr. Stobie is a member of the Washington Society of CertiIied Public Accountants and the American Institute of CertiIied Public Accountants.



ENGAGEMENT

Gray is offering its services as an independent examiner on a limited basis and only after careful consideration of the prospective examinee (Swiss Bank), their internal control structure, their data systems and condition of records, and qualiIications of their supporting professionals. Due to the short term nature of the Program: Gray will only consider a limited number of engagements. Client acceptance of Category 2 Banks will be conducted in November and December of 2013, and for Category 3 and 4 Banks in February through September of 2014. SigniIicant preparations must be made in order to ensure a successful engagement, and as a result, considerable preparations must take place before the Iiling of the letter or intent. Contact Gray to schedule an appointment to discuss engagement alternatives as soon as possible.



CONTACT US

Website: www.grayintl.com

E-mail: [email protected]

Address: U.S. International OfIice (Handling U.S. Tax and Compliance for International Business)

Attn: Jeremy Stobie, CPA, CFE 10900 NE 8th Street Suite 1000 Bellevue, WA 98004

Phone:

+ 001 425.999.3685 xt 10

Gray welcomes your questions, comments and inquiries and would like the opportunity to serve you.


Documents

Swiss Bank Independent Examiner