supervision profile central bank of the bahamas 1....

SUPERVISION PROFILE

CENTRAL BANK OF THE BAHAMAS

1. NAME OF SUPERVISORY AGENCY AND CATEGORY/IES OF FINANCIAL

INSTITUTIONS FOR WHICH IT HAS REGULATORY OVERSIGHT

The Central Bank of The Bahamas is the licensing, registration and supervisory authority for all

banks and trust companies, non-bank money transmission service providers, private trust

companies and their registered representatives operating in and from within The Commonwealth

of The Bahamas.

2. NUMBER AND NAMES OF ENTITIES SUPERVISED IN EACH CATEGORY

As at 31st

December, 2013, there were 267 Banks and/or Trust Companies as follows:-

66 institutions hold banking and trust licenses

36 institutions hold banking licenses only

165 institutions hold trust licenses only

(See appendix for listing of licensees.)

3. PRUDENTIAL INFORMATION/DATA REQUIRED OF LICENSED

INSTITUTIONS AND REPORTING INTERVALS

Central Bank Prudential Reports

Repor

t

Frequency Submitted by:

Bahamian Dollar Open Position Report

Daily Commercial Banks

Form I – Interim Report (Liabilities)

Weekly Commercial Banks and OLFIs

Form II – Interim Report (Assets) Weekly Commercial Banks and OLFIs

Form X – Inter Financial Institutions Transactions Report


Form Z – Interim Report (Interest Rates)


Form Y – Interim Report (Financial Transactions Fluctuations)


Form I – Statement of Liabilities Monthly

Quarterly

Commercial Banks and OLFIs

All Public Licensees

Form II – Statement of Assets Monthly

Quarterly



Form IIA – Statement of Other Assets and Liabilities

Monthly

Quarterly



Form III – Analysis of Deposits by Depositor

Monthly Commercial Banks and OLFIs

Form IIIC – Analysis of Foreign Currency Deposits of Residents


Form IV – Analysis of Loans & Overdrafts (by Sector,

Currency, Maturity)


Form V – Analysis of Consumer Credit


Form X – Analysis of Inter Financial Transactions


Capital Adequacy Statement Monthly

Quarterly

Commercial Banks and OLFIs All Public Licensees

Statement of Assets by Zone Monthly

Quarterly


Statement of Investments Monthly

Quarterly


Statement of Market Loans & Depositors

Monthly

Quarterly


Statement of Large Exposures Monthly

Quarterly



Summary of Non-performing Assets & Provisions

Monthly

Quarterly



Sectoral Exposures Monthly

Quarterly



Large Loan Arrears Monthly

Quarterly



Large Exposures 2 Monthly

Quarterly


Form 3A – Dormant Accounts Report

Quarterly Commercial Banks and OLFIs & All Other Public Licensees

Form 3B – Analysis of Resident B$ Deposits

Quarterly Commercial Banks and OLFIs

Form 5B – Credit Card Report Quarterly Commercial Banks and OLFIs

Form 6 – Mortgages Report (Commercial and Residential)

Quarterly Commercial Banks and OLFIs

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Form 7 – Profit and Loss Statement

Quarterly Commercial Banks and OLFIs & All Other Public Licensees

Form 8 – Analysis of Payments System

Quarterly Commercial Banks

Fiduciary Assets Quarterly Commercial Banks and OLFIs & All Other Public Licensees

Memo Items Quarterly Commercial Banks and OLFIs & All Other Public Licensees

Maturity-Wise Analysis Quarterly Commercial Banks and OLFIs & All Other Public Licensees

Interest Rate Sensitivity Quarterly Commercial Banks and OLFIs & All Other Public Licensees

Investments by Currency Type Quarterly Commercial Banks and OLFIs & All Other Public Licensees

Trading Statistics Quarterly Commercial Banks and OLFIs & All Other Public Licensees

Balance of Payments Statistics Quarterly Commercial Banks and OLFIs & All Other Public Licensees

Form ZZ – International Banking Statistics

Semi-Annually All Public Licensees

Audited Financial Statements Annual All Licensees

Annual Statement Annual All Licensees

Gross Economic Contribution of Banks and Trusts Survey (Annual

Banking Survey)

Annual All Licensees

Financial Sector Survey Annual Other Financial Sector entities – Credit Unions, Insurance Companies, Investment Fund Administrators

Coordinated Portfolio Investment Survey

Annual All Public Licensees

Pension Fund Survey Annual All Public Licensees

4. PRUDENTIAL INFORMATION / DATA PUBLISHED BY SUPERVISORY

AUTHORITY AND PUBLICATION INTERVALS

The following reports are published by the Central Bank:-

Monthly Economic and Financial Developments (website publication) - Monthly

Bank Supervision Letter to Licensees - Quarterly

Statistical Digest – Quarterly

Economic Review – Quarterly

Annual Report – Annual

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5. PRINCIPAL PIECES OF LEGISLATION GOVERNING THE OPERATION OF

BANKING/FINANCIAL LICENSEES (INCLUSIVE OF ANTI-MONEY

LAUNDERING AND ANTI-TERRORISM STATUTES WHERE APPLICABLE)

Principal legislation:

1. The Banks and Trust Companies Regulation Act, 2000

2. The Central Bank of The Bahamas Act, 2000

3. Exchange Control Regulations Act, 1952

4. The Financial Intelligence Unit Act, 2000

5. The Financial Transactions Reporting Act, 2000

6. The Proceeds of Crime Act, 2000

7. The Anti-Terrorism Act, 2004

Subsidiary legislation:

1. Banks and Trust Companies (Licence Application) Regulations, 2002

2. Banks and Trust Companies (Restrictions on Use of Banking Names and Descriptions)

Regulations, 2002

3. Banks and Trust Companies (Foreign Currency Position) Regulations, 2005

4. Banks and Trust Companies (Acquisition of Shares) Regulations, 2005

5. Banks and Trust Companies (Equity Investments) Regulations, 2005

6. Banks and Trust Companies (Payment of Dividends) Regulations, 2005

7. Banks and Trust Companies (New Appointments) Regulations, 2005

8. Banks and Trust Companies (Large Exposures) Regulations, 2006

9. Banks and Trust Companies (Private Trust Companies) Regulations, 2007

10. Banks and Trust Companies (Money Transmission Business) Regulations, 2008

11. Banks and Trust Companies (Temporary Business Continuity) Regulations, 2009

12. Banks and Trust Companies (Auditors) (Facts and Matters of Material Significance)

Regulations, 2011

13. Banks and Trust Companies (Liquidity Risk Management) Regulations, 2012

14. Financial Transactions Reporting Regulations, 2000

15. Financial Intelligence (Transactions Reporting) Regulation, 2001

16. Financial Transactions Reporting (Wire Transfer) Regulations, 2009

6. MAJOR CHANGES TO BANKING/FINANCIAL STATUTES OVER THE PAST

TEN YEARS

Central Bank of The Bahamas (Amendment) Act, 2006 (“the CBA”)

Banks and Trust Companies Regulation (Amendment) Act, 2006 (“the BTCRA”)

Under the BTCRA, the Central Bank issues public trust company, restricted trust company and

nominee trust company licences. The 2006 amendments to the CBA and the BTCRA created a

unique type of trust company known as a Private Trust Company [PTC], which is exempt from

the licensing requirements of the BTCRA otherwise applicable to the preceding list of trust

companies. The regulatory regime for a PTC is designed to ensure high standards of business

conduct, professionalism and competence for PTCs, while offering an appropriate level of

regulatory oversight consistent with the limited activities of such companies. Each PTC must

have a Registered Representative that is resident in The Bahamas. The Registered Representative

http://laws.bahamas.gov.bs/cms/images/LEGISLATION/PRINCIPAL/2000/2000-0038/BanksandTrustCompaniesRegulationAct_1.pdf

http://laws.bahamas.gov.bs/cms/images/LEGISLATION/PRINCIPAL/2000/2000-0037/CentralBankofTheBahamasAct_1.pdf

http://laws.bahamas.gov.bs/cms/images/LEGISLATION/PRINCIPAL/2000/2000-0039/FinancialIntelligenceUnitAct_1.pdf

http://laws.bahamas.gov.bs/cms/images/LEGISLATION/PRINCIPAL/2000/2000-0040/FinancialTransactionsReportingAct_1.pdf

http://laws.bahamas.gov.bs/cms/images/LEGISLATION/PRINCIPAL/2000/2000-0044/ProceedsofCrimeAct_1.pdf

http://laws.bahamas.gov.bs/cms/images/LEGISLATION/PRINCIPAL/2004/2004-0025/Anti-TerrorismAct_1.pdf

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may be a bank and/or trust company licensee of the Central Bank or a Financial and Corporate

Services Provider licensed under the Financial and Corporate Service Providers Act, 2000

(FCSPA). PTCs are, by their nature, often formed to act as trustee of a single trust, or a

group of related trusts. PTCs provide a convenient means of transferring control and influence

over family business interests, wealth and assets as the Board of Directors of a PTC would

normally consist of family members of the settlor.

Central Bank of The Bahamas (Amendment) Act, 2007

Banks and Trust Companies Regulation (Amendment) Act, 2007

The Banks and Trust Companies Regulation (Amendment) Act, 2007 repealed and replaced

section 19(6) of the BTCRA and repealed the Second Schedule of the BTCRA, with the effect

of:-

i. expanding the category of domestic financial services regulators with whom the Central

Bank may cooperate and share information, to include all domestic financial services

regulatory authorities;

ii. expanding the category of persons within the Central Bank who may cooperate with and release information to domestic regulators to include a director, officer, employee, agent or advisor of the Bank;

iii. expanding the category of information that the Central Bank may share with domestic

regulators (which previously only included information on the beneficial owners,

directors, officers and operations of a licensee and any of its affiliates), to include any

other information acquired in the discharge of the Bank’s functions and duties under the

BTCRA or any other Act, where the Governor considers that such cooperation or

information may be relevant to the functions of such other regulatory authority, or as a

necessary part of a framework for consolidated supervision, oversight or regulation of

the financial services sector;

iv. the prior approval of the Governor is required for any cooperation or information

sharing between the Central Bank and other domestic financial services regulators

pursuant to section 19(6).

Substantially the same change was effected by the Central Bank of The Bahamas (Amendment)

Act, 2007 with the insertion of a new section 38(9) in the CBA.



The 2008 legislative amendments inter alia, enable the Central Bank to supervise non-

bank money transmission businesses for operational integrity and for anti-money laundering and

countering the financing of terrorism (AML/CFT) purposes.

Banks and Trust Companies (Licence Application) (Amendment) Regulations, 2008

These Regulations revise the documentary requirements for applicants seeking to become

licensees of the Central Bank. The bank no longer requires a detailed net worth statement for

applicants who seek to acquire shareholdings in licensees of less than 10% but permits such

applicants to submit net worth statements, which certify that their net worth is at least five (5)

times the value of the share capital to be acquired. The Regulations also permit the Bank to

accept, in lieu of two character references, a letter of good standing from the home regulator of

proposed licensees, which have parent companies domiciled in specified categories of countries.

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The Act was amended as follows with effect from 1st

September, 2010:

The requirement for licensees to publish their annual audited financial statements in

the Gazette was removed and replaced with a provision which gives the Central Bank the

discretion to allow licensees to publish these statements in such manner and form as the

Bank determines.

The requirement for licensees to obtain the Bank’s prior approval for the appointment

of auditors was replaced by a new requirement for licensees to give the Bank notice of the

appointment within fourteen days of the appointment; the Bank, however, retains the right

to require the removal of an auditor of a licensee.

Auditors and former auditors of licensees are required to provide the Inspector of Banks

and Trust Companies (the Inspector) with written notice of specified matters including

any fact or matter of which the auditor or former auditor has/had become aware in the

ordinary course of an audit and which is of material significance to the discharge of the

Inspector’s functions under the BTCRA. An auditor must also disclose his/her intention to

resign before expiration of his/her term.

The time for commencing prosecutions for summary offences committed under the

BTCRA has been extended. Previously, prosecutions had to be commenced within a

maximum of six months from the commission of the offence (as provided under the

Criminal Procedure Code). Prosecutions may now be commenced either twelve months

from the date of the commission of the offence or within three months of the date on

which the Attorney General forms the view that there is sufficient evidence to justify the

prosecution of the offence under the BTCRA, whichever is later.

A distinction has been made between the surrender of a licence granted under the

BTCRA and a revocation of such licence and the amendment permits licensees to

surrender their licences provided certain specified pre-conditions are met.

The Bank was authorized to publish specified enforcement actions, which it takes

against licensees.


The Act was amended with effect from 1st

September, 2010 as follows:

Section 5 was amended to expand the duties of the Bank to include responsibility

for the stability of the financial system and oversight of the operation and regulation of

payment and securities settlement systems.

Section 25 was amended to expressly authorize the Central Bank to regulate and oversee

payment and securities settlement systems and payment instruments including

electronic money.

Banks and Trust Companies (Money Transmission Business) (Amendment) Regulations, 2011

The Schedule of the Regulations was amended to introduce a new fee to be paid by money

transmission service providers in respect of each location where a money transmission agent

operates on behalf of the service provider.

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Financial and Corporate Service Providers (Amendment) Act, 2008 which inter alia:

removed requirement for Financial and Corporate Services Providers (FCSPs) to have

licences renewed annually;

empowered the Inspector of Financial and Corporate Services (Inspector FCS) to issue

rules, guidelines, and directives to FCSPs;

broadened the sanctioning power of the Inspector FCS (s. 18A); and

provided a right of appeal to the Supreme Court where the Inspector imposes a sanction

under s. 18A (1) (see S. 19(1) (c)).

Financial Transactions Reporting (Amendment) Act, 2008

Broadens the category of eligible introducers upon which financial institutions may

rely, subject to the guidance and directions of a financial institution’s supervisory

authority. Where financial institution A relies on the written confirmation of financial

institution B that financial institution B has verified the identity of a customer who seeks

to establish a business relationship with financial institution A, financial institution B will

be regarded as an introducer.

Requires auditors to report suspicious transactions to the FIU instead of to the Police.

Provides that where a financial institution has been liquidated and finally dissolved,

the liquidator must maintain the transaction and verification records of the liquidated

financial institution for the balance of the prescribed five-year period remaining at the

date of dissolution.

Makes it an offence for a financial institution to violate or fail to comply with any

provision of any code of practice issued by the Compliance Commission.

Financial Transactions Reporting (Amendment) Regulations, 2009

The amended Regulations require certain mandatory identification evidence in the case of

corporate entities, partnerships and unincorporated businesses and requires licensees to undertake

full customer due diligence measures in respect of entities that are subject to reduced due

diligence when there is a suspicion of money laundering or terrorist financing.

7. AREAS IDENTIFIED FOR FURTHER LEGISLATIVE CHANGES AND

DETAILS/STATUS OF ANY NOW IN PROCESS

The Banks and Trust Companies Regulation (Amendment) Bill, 2014 and the draft Banks and

Trust (Administrative Monetary Penalties) Regulations, 2014 together seek to expand the

Bank’s powers to impose administrative monetary penalties for breaches of the principal Act or

regulations made thereunder, or non-compliance with any direction, order, condition or limitation

made by the Bank. The proposed amendments to the principal Act also seek to enhance the fit

and proper requirements and include new provisions relating to controllers of licensees and to

empower the Bank to impose prohibition orders against persons performing regulated

functions, where persons do not, or no longer, meet the Bank’s fit and proper

requirements.

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The Central Bank is set to take statutory responsibility for the prudential regulation and supervision of credit unions and, in preparation for this new responsibility, has drafted the Bahamas Co-operative Credit Unions Bill together with a compendium of other related draft Bills and Regulations which were disseminated for public consultation and are expected to be enacted later this year. It is also proposed that the Central Bank will be responsible for the regulation of the credit reporting sector in The Bahamas. In this regard, work on the draft Credit Reporting Bill and Regulations are significantly advanced and are expected to be issued for public consultation and enacted later this year.

8. FORMAL DIRECTIVES, POLICIES, GUIDELINES/GUIDANCE NOTES

ISSUED BY SUPERVISORY AUTHORITY TO LICENSEES

The Central Bank of The Bahamas has issued the following Guidelines:-

Prudential Limits and Restrictions:

Country Risk Management

Capital Adequacy

Measurement, Monitoring and Control of Impaired Assets

Large Exposures Requirement

Management of Liquidity Risk

Management of Credit Risk

Management of Market Risk

Management of Interest Rate Risk

Operational Guidelines:

Business Continuity Planning Electronic Banking Minimum Standards for Outsourcing of Material Functions Management of Operational Risk

Corporate Governance:

Corporate Governance of Banks and Trust Companies Licensed to do Business Within and from Within The Bahamas

Anti-Money Laundering/CFT:

Assessing the Fitness and Propriety of Money Laundering Reporting Officers (MLRO) in the Bahamas

Prevention of Money Laundering and Countering the Financing of Terrorism

Regulated Functions:

Relationship Between External Auditors of Licensees and the Central Bank

Establishment or Acquisition of Overseas Branches, Subsidiaries and Representative

Offices

Minimum Standards for Character and Financial Reference Letters

Assessing the Fitness and Propriety of Applications for Regulated Functions

General Information:

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A Guide to the Central Bank’s On-site Examination Process

A Guide to the Central Bank’s Ladder of Supervisory Intervention

Procedures for Voluntary Liquidations and the Subsequent Revocation of a Banking or

Trust Licence

Minimum Standards for Letters of Comfort and Parental Guarantees

General Information and Guidelines for Licence Applications for Banking and/or Trust

Companies

General Information and Application Guidelines for Non-Bank Money Transmission

Service Providers and Non-Bank Money Transmission Agents

General Information and Application Guidelines for Private Trust Companies and Their

Registered Representatives

Administration and Ultimate Transfer of Dormant Accounts to the Central Bank of The

Bahamas

Dormant Accounts Web Reporting System

Physical Presence & Managed Licensees Guidelines:

Minimum Physical Presence Requirements for Banks and Trust Companies Licensed in The

Bahamas

Managed Licensees

Managed Branches

Policies and Guidance Notes:

Reliance on Third Parties to Conduct KYC on Customers

Exemption on Private Trust Companies (PTCs) from BTCRA 6(1)

Guidance Note on Section (7) of the BTCRA (Prohibited Words)

Supervision of Nominee Activities of Subsidiaries and Related Companies of Banks and

Trust Companies (Revised) : (GN:1 – 06/07 rev. [07/07]

o Additional Explanation: Supervision of Nominee Activities of Subsidiaries and

Related Companies of Banks and Trust Companies [GN:01- 03/08]

o Supervision of Nominee Activities of Subsidiaries and Related Companies of Banks

and Trust Companies (GN: 01-03/08) rev.[04/11]

Guidance Notice: Waiver of Minimum Number of Shareholders Requirement for

Applicants for a Restricted Bank and/or Trust Company Licence

The Relationship between External Auditors of Licensees and the Central Bank

Annual Publication of Audited Financial Statements

Guidance Note on Accounting and Other Records

Guidance Notes for the Completion of the Excel Reporting System

Listing of Reporting Forms for the Excel Reporting System

Listing of Central Bank Prudential Reports

Handbook on Information Sharing Arrangement in The Bahamas

General Prudential Norms

In the immediate future, the Central Bank will commence industry consultation on several key draft policy guidelines:-

http://www.centralbankbahamas.com/legal_guidelines.php?cmd=view&id=11937

http://www.centralbankbahamas.com/legal_guidelines.php?cmd=view&id=11937

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1. Draft Guidelines for Minimum Disclosures

The Guidelines for Minimum Disclosures will set out the minimum requirements for Pillar III

disclosures.

In addition to specific industry guidelines and regulations, there are other Notes and Notices that the

Bank Supervision Department publishes, covering an array of financial sector issues. These

documents are listed below in reverse chronological order.

1. Related Party Transactions

2. Reporting of Material Events and Incidents of Fraud

3. AML, KYC and CFT Best Practices

4. Protocol for Joint On-site Examinations

5. Timelines for Processing Applications and Other Official Requests

6. Extract from Basel III – A Global Regulatory Framework for More Resilient Banks and

Banking Systems

7. Phase–in Arrangements for Basel Capital Standards

8. Group Structures of Licensees

9. Reporting of Unverified Facilities and Development of an Anti-Money Laundering Risk

Framework

9. STATUS OF JURISDICTION VIS-Á-VIS BASEL CORE PRINCIPLES OF

BANKING SUPERVISION

In 2012, the International Monetary Fund conducted a Module 2 Assessment of the Bahamas’

regulation of the banking sector against the Basel Core Principles for Effective Banking

Supervision. The following ratings were given by the IMF’s assessment team:

Compliant Largely

Complian

t

Materially Non- Compliant

Non- Compliant

Not Applicabl

e 21 9 0 0 0

The Central Bank has since the 2012 IMF review sought on an on-going basis, to enhance its regulatory framework and improve overall compliance with the Basel Core Principles.

The Central Bank has developed an Action Plan for enhancing compliance with the Core

Principles and continues its self-assessment against the Basel Core Principles.

10. JURISDICTION STATUS VIS Á VIS FINANCIAL SECTOR ASSESSMENT

PROGRAMME (FSAP)

During July 9 - 31, 2012, the International Monetary Fund (IMF) led a mission to conduct a

Financial Sector Assessment Program (FSAP) in respect of The Bahamas’ financial services

sector. For the Central Bank, the focus was on assessing compliance with the Basel Core

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Principles for Effective Banking Supervision (BCP) and included the review of the legislative

and regulatory framework for banking supervision. There was also an in-depth focus on interbank

connectivity and the transmission of global economic shocks, as well as stress testing of the

domestic banking system’s vulnerability to plausible shocks. The reports of the IMF mission to

The Bahamas, under the Financial Sector Assessment Program including the Detailed Assessment

Report were finalized in December 2012.

The IMF broadly recognized that The Bahamas has in place a very strong legal and regulatory

framework for banking supervision and that significant changes have occurred in The Bahamas’

financial system and the supervisory regime since the 2004 Offshore Financial Centre Assessment

of the jurisdiction. Licensing and supervision of offshore entities is supported by effective

information sharing with home supervisors and participation in regulatory colleges. Banking

supervision is strong. The Central Bank implemented a Risk Based Supervisory Framework

(Framework), in the last quarter of 2010, pursuant to which, the Bank reviews all risk areas and

assigns ratings to licensees to aid in establishing supervisory priorities. The Framework also

established the foundation for the Bank’s approach to Pillar II requirements under the Basel II

regime.

Notwithstanding these developments, the IMF made several recommendations with respect to

regulatory improvements in the financial sector. The recommendations were specific to prudential

regulatory requirements and covered inter alia consolidated and cross-border banking supervision,

operational risks and the issuance of guidelines detailing Central Bank’s approach to consolidated

supervision. Although existing legislation provides the Central Bank with broad authority to

conduct consolidated supervision, issuing detailed guidelines would enhance transparency and

achieve uniformity.

A number of initiatives are already underway that will allow The Bahamas to enhance its banking

supervision legislative regime and policy framework to comply with the Basel Core Principles.

The Central Bank intends to have the draft Banks and Trust Companies Regulation (Amendment)

Bill, 2014 enacted and to bring the draft Banks and Trust Companies (Administrative Monetary

Penalties) Regulations, 2014 (the Regulations) into force in the near future. The draft Bill will

strengthen and clarify the Central Bank’s existing penalties enforcement regime by empowering

the Central Bank to impose administrative monetary penalties or fines on any person or licensee

in respect of the contravention of the Banks and Trust Companies Regulation Act, 2000 (the Act)

or regulations made under the Act.

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APPENDIX

Central Bank Licensees as of 31st

December, 2013

Public Banks

Banco BBM S/A

Banco de Bogota (Nassau) Ltd.

Banco Espirito Santo, S.A.

Banco Itaú BBA S.A.

Banco Santander (México), S.A., Institución de Banca Múltiple, Grupo Financiero Santander México

Banco Santander Bahamas Int'l Ltd.

Banco Votorantim S.A.

Bank of Baroda

Bank of Nova Scotia Int'l Ltd.

Bank of Nova Scotia, The

BMO Harris Bank N.A.

BSI Overseas (Bahamas) Ltd.

Citibank Central America (Nassau) Ltd.

Citicorp Banking Corp.

Commonwealth Bank Ltd.

Coral Credit Bank Ltd.

Fidelity Bank (Bahamas) Ltd.

Hang Seng Bank (Bahamas) Ltd.

HongKong & Shanghai Banking Corp. Ltd., The

HSBC Bank Bahamas Ltd.

Latin American Investment Bank Bahamas Ltd.

Metropolitan Bank (Bahamas) Ltd.

PNC Bank, N.A.

Royal Bank of Canada

Santander Investment Bank Ltd.

Scotiabank (Bahamas) Ltd.

Scotiabank Caribbean Treasury Ltd.

Standard Chartered Bank

State Bank of India

Union Bancaire Privée (Bahamas) Ltd.

Votorantim Bank Ltd.

Public Bank & Trust Companies

Andbank (Bahamas) Ltd.

Ansbacher (Bahamas) Ltd.

Arner Bank & Trust (Bahamas) Ltd.

Austrobank (Overseas) Ltd. [In Liquidation]

BAC Bahamas Bank Ltd.

Banca del Sempione (Overseas) Ltd.

Banco Atlantico (Bahamas) Bank & Trust Ltd. [In Liquidation]

Banco Nacional de Mexico S.A., integrante del Grupo Financiero Banamex

Banif Int'l Bank Ltd.

Bank J. Safra Sarasin (Bahamas) Ltd.

Bank of Nova Scotia Trust Co. (Bahamas) Ltd., The

Cont’d in Column 2, Pg 17

Bank of The Bahamas Ltd.

Banque Privee Edmond de Rothschild Ltd.

BBM Bank Ltd.

BSI AG

Butterfield Trust (Bahamas) Ltd.

CBH (Bahamas) Ltd.

CIBC Trust Co. (Bahamas) Ltd.

Citco Bank & Trust Co. (Bahamas) Ltd.

Citibank, N.A.

Cititrust (Bahamas) Ltd.

Corner Bank (Overseas) Ltd.

Credit Agricole Suisse (Bahamas) Ltd.

Credit Suisse AG

Credit Suisse Brazil (Bahamas) Ltd.

Dartley Bank & Trust Ltd.

Deltec Bank & Trust Ltd.

Deutsche Bank Trust Co. Americas

EFG Bank & Trust (Bahamas) Ltd

Eurobanco Bank Ltd.

Finance Corp. of Bahamas Ltd.

First Overseas Bank Ltd.

First Trust Bank Ltd.

FirstCaribbean Int'l Bank (Bahamas) Ltd.

Gonet Bank & Trust Ltd.

Guaranty Trust Bank Ltd.

Habib Banking Corp. Ltd. [In Liquidation]

Heath Bank & Trust Ltd.

Hottinger Bank & Trust Ltd.

Inteligo Bank Ltd.

Itaú Bank & Trust Bahamas Ltd.

J.P. Morgan Trust Co. (Bahamas) Ltd.

JPMorgan Chase Bank

Julius Baer Bank & Trust (Bahamas) Ltd.

Lombard Odier & Cie (Bahamas) Ltd.

Macro Bank Ltd.

Mizuho Bank (USA)

MMG Bank & Trust Ltd.

Pasche Bank & Trust Ltd.

Pictet Bank & Trust Ltd.

Private Investment Bank Ltd.

RBC Royal Bank (Bahamas) Ltd.

Royal Bank of Canada Trust Co. (Bahamas) Ltd.

Royal Fidelity Merchant Bank & Trust Ltd.

Santander Bank & Trust Ltd.

Société Générale Private Banking (Bahamas) Ltd.

St. James Bank & Trust Co. Ltd., The


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Syz & Co. Bank & Trust Ltd.

UBS (Bahamas) Ltd.

Union Bancaire Privée, UBP SA

Westrust Bank (Int'l) Ltd.

Winterbotham Trust Co. Ltd., The

Public Trust Companies

Bamont Trust Co. Ltd.

BSI Trust Corp. (Bahamas) Ltd.

CAMS (Bahamas) Ltd.

Cayside Trust Co. Ltd.

Credit Suisse Trust Ltd.

Equity Trust Bahamas Ltd.

Euro-Dutch Trust Co. (Bahamas) Ltd.

Hang Seng Bank Trustee Int'l Ltd.

Heritage Trust Co. Ltd., The

Integritas Trust Co. Ltd.

Intertrust (Bahamas) Ltd.

Julius Baer Trust Co. (Bahamas) Ltd.

Private Trust Corp. Ltd., The

Rhone Trustees (Bahamas) Ltd.

UBP Int'l Trust Ltd.

UBS Trustees (Bahamas) Ltd.

Restricted Banks

Investindustrial Bank Ltd.

Liverpool-West Indies Bank Ltd.

Restricted Bank & Trust Companies

Belgravia Int'l Bank & Trust Co. Ltd.

Fidelity Bank & Trust Int'l Ltd.

Restricted Nominee Trust Companies

A.C.D. Ltd.

A.N.D. Ltd.

Adansonia Investments Ltd.

Administrative Directors Ltd.

Administrative Holdings Ltd.

Administrative Managers Ltd.

Albacore Investments Ltd.

Alpine Services Ltd.

Amazonas Investments Ltd.

Amber Nominees Ltd.

Angleberry Ltd.

Arabon Management Holdings Ltd.

Arawak Bay Ltd.

Badeira Management Ltd.

BAHTCO Holdings Ltd.

Baird One Ltd.

Bank of The Bahamas Trust Ltd.

Baraterre Ltd.

BdS Corporate Services Ltd.


Beacon Nominees Ltd.

Beaumont Nominees Ltd.

Boyne Ltd.

Business Management Ltd.

C.B. Management Ltd.

C.B. Strategy Ltd.

Calpas Ltd.

Carib Bay Ltd.

Carnoustie Ltd.

Castor Management Ltd.

CBT (Bahamas) Ltd.

CBT Management Ltd.

Cellgroove Ltd.

Cerchio Ltd.

Chester Asset Holdings Ltd.

Circle Corporate Services Ltd.

Coen River Corp.

Commerce Services Ltd.

Corporate Associates Ltd.

Delacroix Ltd.

Delaroche Ltd.

Dirmac Ltd.

Dixon Hill Ltd.

Dolfort Director Ltd.

Donat Investments S.A.

Dorwinona Ltd.

Dowberry Ltd.

Dunmore Properties Ltd.

East Bay Protector Services Ltd.

Ebony Nominees Ltd.

Eradani Ltd.

Erie Ltd.

Fife Ltd.

First Directorships Ltd.

First Nat'l Nominees Ltd.

FirstCaribbean Int'l (Bahamas) Nominees Co. Ltd.

Fornacis Ltd.

Fourth Directorships Ltd.

Frederick Investments Ltd.

Geminorum Ltd.

Grahamco Ltd.

Gresham Nominees Ltd.

GTC Nominee Ltd.

Hamaca Nominee Ltd.

Hitchcock Investments S.A.

Huron Secretarial Services Ltd.

Hyksos Ltd.

Itau Bahamas Directors Ltd.


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Itau Bahamas Nominees Ltd.

Ivory Nominees Ltd.

Ivyberry Ltd.

James Bay Ltd.

Jazzberry Ltd.

Jedburgh Ltd.

La Falaise Management Ltd.

Lascol Ltd.

LTSB Nominees Ltd.

M.T.B. Clients Nominees Ltd.

Madeleine Investments S.A.

Manella Management Holdings Ltd.

March Ltd.

Maridi Investment Co. Ltd.

Mehi River Corp.

Mercury Nominees Ltd.

Montague East Ltd.

Morfontaine Ltd.

Nassbarr Investments Corp.

Nassnom Investments Corp.

Niford Ltd.

Nomark Ltd.

Nomco Ltd.

Nomnass Investments Corp.

Octagon Management Ltd.

Orion Nominees Ltd.

Paladin Nominees Ltd.

Pelican Investments Ltd.

Pollux Corporate Services Ltd.

Providence Associates Ltd.

PTC Investment Holdings Ltd.

Pyke Ltd.

Remus Investments Ltd.

Ripere Director Ltd.

Rolleville Ltd.

Romulus Investments Ltd.

Saintco Ltd.

Scotia Nominees (Bahamas) Ltd.

Second Directorships Ltd.

Sentinel Nominees Ltd.

Sfera Ltd.

SJBTC Ltd.

Sterling East Ltd.

Superior Ltd.

Tarpumbay Ltd.

Thika Holdings Ltd.

Third Directorships Ltd.

Three Keys Ltd.


Tia River Corp.

Triangle Administration Ltd.

UCE Directors S.A.

UCE Management S.A.

UCE Secretaries S.A.

Ungava Bay Ltd.

Universal Administrators Ltd.

Universal Directors Ltd.

Universal Shareholders Co. Ltd.

Vialink Nominees Ltd.

Welland Ltd.

Winooski Ltd.

WND Ltd.

WNS Ltd.

WTD Ltd.

Wuhu Ltd.

Yarra Nominees Ltd.

Restricted Trust Companies

Anco Trust Corp. Ltd.

Ark Ltd.

Arndilly Trust Co. Ltd.

Bitmore Ltd.

Cromwell Trust Co. Ltd.

Glen Trust Co. Ltd., The

Governors Trust Co. Ltd.

Grampian Trust Co. Ltd.

Hermes Trust Co. Ltd.

Laurentide Insurance & Mortgage Co. Ltd.

Marien Holdings (Bahamas) Ltd.

Portland Trustee Ltd.

Ranco Capital Trust Group Ltd.

SG Hambros Corporate Services (Bahamas) Ltd.

TK Trust Co. Ltd., The

Troika Trust Ltd.

Non-Active Banks

Gulf Union Bank (Bahamas) Ltd. [In Liquidation]

Lloyds TSB Bahamas (Americas) Ltd. [In Liquidation]

Standard Chartered Bank Bahamas Ltd. [In Liquidation]

Non-Active Bank & Trust Companies

Lloyds TSB Bank & Trust (Bahamas) Ltd. [In Liquidation]

Socimer Int'l Bank Ltd. [In Liquidation]

Non-Active Trust Companies

Canbank Nominees (Nassau) Ltd. [In Liquidation]

See Definitions of Appendix Terms at Pg 20

15

APPENDIX EXPLANATORY NOTES:

Public Licensee:

A public bank and/or trust company is one which is permitted to carry on banking and/or trust business with members of the public.

Restricted Licensee:

A restricted bank and/or trust company is one which is allowed to carry on business for certain specified persons which are usually named in the licence.

Nominee Trust Licensee:

A Nominee Trust licence restricts the services that may be offered by a licensee to the provision of nominee services only. Such services are defined to include the holding of securities and other assets in the licensee’s name and the provision of corporate directors and officers on behalf of its parent company’s clients.

Non-Active Licensee:

A non-active company is either in voluntary liquidation or is an approved dormant licensee.

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