Reyl Overseas Ltd.

Event Detail: NO FORMAL CHARGES WERE BROUGHT AGAINST REYL & CIE S.A. OR MR. FRANCOIS REYL. Status: Final Disposition: THIS LED ON 5 JANUARY 2016, TO A NON-PROSECUTION SETTLEMENT AGREEMENT CONCERNING SIX OF THESE CLIENTS, WHEREBY REYL & CIE S.A. AGREED TO PAY A EUR 2.8 MILLION FINE AND EUR 100,000 IN INDEMNIFICATION COSTS TO THE FRENCH STATE. FRANÇOIS REYL WAS GRANTED A FULLY DISCHARGE. Summary: REYL & CIE S.A. AND MR. FRANCOIS REYL WERE ALLEGED TO HAVE BEEN INVOLVED WITH MONEY LAUNDERING IN CONNECTION WITH TAX EVASION ACTIVITIES OF APPROXIMATELY 32 ALLEGED CLIENTS OF REYL & CIE S.A. REYL & CIE S.A. ENTERED INTO A NON-PROSECUTION SETTLEMENT AGREEMENT ON JANUARY 5, 2016 REGARDING CLAIMS OF ALLEGED MONEY LAUNDERING RELATED TO TAX EVASION CHARGES AGAINST SIX (6) FRENCH RESIDENTS. REYL & CIE S.A. WAS GRANTED A DISCHARGE FROM CASES REGARDING THE REMAINING TWENTY SIX (26) ALLEGED CLIENTS. MR. FRANCOIS REYL HAS BEEN GRANTED A COMPLETE DISCHARGE FROM THIS MATTER, AS THE JUDGES CONSIDERED HE HAS NOT COMMITTED ANY OFFENCE.

Event Detail: NO FORMAL CHARGES WERE OR WILL BE BROUGHT AGAINST REYL & CIE S.A. AND MR. FRANCOIS REYL. Status: Final Disposition: ON 18 APRIL 2023, REYL & CIE AND FRANÇOIS REYL ENTERED INTO A NON-PROSECUTION SETTLEMENT AGREEMENT UNDER WHICH REYL & CIE HAS TO PAY EUR 5,750,000 AND MR. FRANÇOIS REYL AN AMOUNT OF EUR 500'000 IN RELATION WITH THIS LAST CLIENT. REDUCED TO RESPECTIVELY EUR 1,0750,000 AND EUR 125,000 BY APPLICATION OF THE CONFUSION DES PEINES MECHANISM. Summary: AS REGARDS THE LAST CLIENT, THE FRENCH INVESTIGATING JUDGE DECIDED TO DISCONNECT THIS CASE FROM THE OTHERS AND THE INVESTIGATIONS KEPT ON. THIS DECISION WAS BASED ON THE FACT THAT SAID CLIENT AS SUSPECTED OF HAVING USED A TRUST TO EVADE TAXES IN FRANCE ALLTHOUGH HE HAD, AS SOON AS HE BECAME A FRENCH TAX RESIDENT, DISCLOSED THE VERY EXISTENCE OF THIS TRUST TO THE FRENCH FISCAL AUTHORITIES BY LETTER DATED 26 NOVEMBER 2009. THE CLIENT FOUND AN AGREEMENT WITH THE FRENCH TAX AUTHORITIES FOR THE FISCAL PROCEEDING.

Event Detail: REYL & CIE SA AND MR. FRANCOIS REYL WERE CHARGED WITH ONE COUNT OF ALLEGED MONEY LAUNDERING IN CONNECTION WITH A TAX OFFENCE. THEY PLED NOT GUILTY. Status: Final Disposition: BY A JUDGEMENT RENDERED ON DECEMBER 8, 2016, THE PARIS CRIMINAL COURT (TRIBUNAL CORRECTIONNEL DE PARIS) FOUND REYL & CIE SA AND MR. FRANCOIS REYL GUILTY OF LAUNDERING OF TAX FRAUD PROCEEDS. REYL & CIE SA WAS FINED EUR 1,875,000. MR. FRANÇOIS REYL WAS (I) FINED EUR 375,000, AND (II) TO A 12-MONTH SUSPENDED JAIL SENTENCE. Summary: ON 18 APRIL 2013, A FRENCH INVESTIGATING JUDGE BEGAN CRIMINAL PROCEEDINGS IN THE CONTEXT OF THE CASE AGAINST A FRENCH RESIDENT, A CLIENT OF REYL & CIE WHO IN 2009 HAD TRANSFERRED ASSETS AMOUNTING TO EUR 600.000 TO JULIUS BAER IN SINGAPORE. THIS RESULTED IN THE CONDEMNATION, ON 8 DECEMBER 2016, OF REYL & CIE, TO A FINE AMOUNTING TO EUR 1.875.000 AND FRANÇOIS REYL TO A FINE OF EUR 375.000 TOGETHER WITH A SUSPENDED SENTENCE OF TWELVE MONTH.