(rr) Compliance with Money Laundering Laws. The operations of the Company are and
have been conducted at all times in compliance with applicable financial recordkeeping and reporting requirements, including those of the U.S. Bank Secrecy Act, as amended by Title III of the Uniting and Strengthening America by Providing
Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (USA PATRIOT Act), and the applicable anti-money laundering statutes of jurisdictions where the Company conducts business and the applicable rules
and regulations thereunder and any related or similar rules, regulations or guidelines, issued, administered or enforced by any governmental agency (collectively, the Anti-Money Laundering Laws), and no action, suit or
proceeding by or before any court or governmental agency, authority or body or any arbitrator involving the Company with respect to the Anti-Money Laundering Laws is pending or, to the Companys knowledge, threatened.
(ss) Compliance with OFAC Regulations.
(i) Neither the Company nor any of its directors or officers nor, to the Companys knowledge, any employee agent, affiliate,
representative or other person acting on behalf of the Company, is an individual or entity, or a Person, that is, or is owned or controlled by a Person that is: (i) the subject of any sanctions administered or enforced by the U.S. Department of
Treasurys Office of Foreign Assets Control (OFAC), the United Nations Security Council (UNSC), the European Union (EU), Her Majestys Treasury
(HMT), or other relevant sanctions authority (collectively, Sanctions), nor (ii) located, organized or resident in a country or territory that is the subject of a U.S. government embargo
(including, without limitation, Cuba, Iran, North Korea, Syria and the Crimea).
(ii) The Company will not, directly or indirectly, use the
proceeds of the offering, or lend, contribute or otherwise make available such proceeds to any subsidiary, joint venture partner or other Person: (i) to fund or facilitate any activities or business of or with any Person that, at the time of
such funding or facilitation, is the subject of Sanctions, or in any country or territory that, at the time of such funding or facilitation, is the subject of a U.S. government embargo; or (ii) in any other manner that will result in a
violation of Sanctions by any Person (including any Person participating in the offering, whether as underwriter, advisor, investor or otherwise).
(iii) For the past five (5) years, the Company has not knowingly engaged in and is not now knowingly engaged in any dealings or
transactions with any Person that at the time of the dealing or transaction is or was the subject of Sanctions or any country or territory that, at the time of the dealing or transaction is or was the subject of a U.S. government embargo.
(tt) No Associated Persons; FINRA Matters. The Company does not directly or indirectly control, is not controlled by, or is not under
common control with, or is not an associated person (within the meaning of Article I, Section 1(ee) of the By-laws of FINRA) of, any member firm of FINRA.
(uu) Cybersecurity; Data Protection. Except as could not be expected to have a Material Adverse Effect, the Companys information
technology assets and equipment, computers, systems, networks, hardware, software, websites, applications, and databases (collectively, IT Systems) are adequate for, and operate and perform in all material respects as
required in connection with
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