Alantra Life Settlements

Compliance Policies & Procedures

Policy

Alantra Life Management Company (the "Company") has adopted this Anti-Money Laundering Program: Compliance Policies and Procedures (the "AML Program") in order to voluntarily embrace the salient anti-money laundering ("AML") principles applicable to life insurance companies under the Bank Secrecy Act (the "BSA") and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (" USA PATRIOT Act"). These principles include:

1. Establishing internal policies, procedures and controls for the Company's prevention and detection of money laundering;

2. Designating an AML Compliance Officer of the Company;

3. Establishing an AML training program for the Company's employees; and

4. Conducting periodic, independent audits of the efficacy of the AML Program.

It is the Company's policy to detect, prohibit and actively prevent money laundering and the financing of terrorist activities through settlement transactions in which the Company purchases in-force life insurance policies (hereinafter referred to as "life settlements"). This AML Program documents the steps the Company and its employees will take to detect, prevent and report money laundering, as well as the records retention, employee training and compliance-testing attendant thereto.

AML Compliance Officer

The Company will designate an individual as its AML Compliance Officer, who shall have responsibility for all aspects of the implementation and effectiveness of the Company's AML Program. The Company's Manager shall approve the appointment of the AML Compliance Officer. The AML Compliance Officer has authority to and shall monitor the Company's compliance with all applicable AML laws and regulations; oversee employee training; and ensure that a proper record retention plan is implemented.

Screening For And Detecting Suspicious Activity And Money Laundering

It is the responsibility of the AML Compliance Officer to continuously monitor the Company's new life settlement transactions as well to detect evidence of any money laundering or terrorist financing in connection with life insurance policies that the Company may broker or life settlement transactions to which the Company may be a party. Significant factors that the Company will monitor are the duration for which a policyowner's life insurance policy has been in-force and whether the insurance company that has issued such policy is a U.S. domiciled insurer. The Company will scrutinize unusual life settlement transactions to determine if the transaction makes financial sense or if it involves an unusual strategy for the policyowner attempting to sell his or her life insurance policy. The Company's new solicitation and representation standards shall be modified as deemed appropriate by the AML Compliance Officer to ensure the Company collects, analyzes and uses all information permitted by law and any other information reasonably necessary to detect and prevent money laundering and terrorist financing through the settlement transactions effected by the Company.

Red Flags for Money Laundering

The U.S. Treasury Department has identified permanent life insurance polices that have a cash surrender value, term life insurance policies, annuity contracts and any other insurance related products that have elements of stored value and transferability as products that pose a significant risk for money laundering. Accordingly, the Company's representatives must be alert for the existence of any indicia of money laundering being conducted involving these types of products, which are the types of products that the Company frequently brokers as life settlements.

The Company has identified several indicia of potential money laundering, or "red flags," that signal possible money laundering or terrorist financing in connection with a life insurance settlement transaction. The potential indicia may include:

The party with whom the Company is conducting the transaction (i.e., the policyowner or applicant for a life settlement or a settlement provider):

a: exhibits unusually high concern for secrecy or concern regarding the proposed settlement transaction, the Company's AML policies or other reporting procedures;

b. is, in the case of a life insurance policy originally purchased in connection with a business (e.g., key person life insurance), reluctant to reveal to the Company information concerning the nature of his or her specific business or does not seem to be fully aware of the nature of the business;

• is acting for an undisclosed principal;

• furnishes suspect identifying documents or is implicated in criminal or regulatory violations, especially ones involving finances;

• provides to the Company information that is false, misleading, or substantially incorrect; or

• exhibits a lack of concern regarding the amount of the net settlement proceeds or transaction costs and is willing to receive substantially less than a market settlement rate, suggesting the party may be seeking to quickly sell the life insurance policy.

The transaction:

a. involves a life insurance policy that was originally issued and delivered in a jurisdiction located outside the United States;

b. involves a life insurance policy that has previously been sold in the secondary life insurance market, or the policyowner refuses to identify all prior owners of the life insurance policy;

c. lacks business sense or purpose or an apparent investment strategy, or is inconsistent with the party's stated business or investment strategy; or

d. involves the transfer of funds by the Company to countries that maintain high bank secrecy or are considered "tax havens" with no clear business reason for involving operations in those countries, including those countries identified by the U.S. Government or FATF as "non-cooperating." FATF publishes its current list of non-cooperating countries on its Web site at: http://www1.oecd.org/fatf/NCCT_en.htm. FinCEN publishes advisories concerning non-cooperating countries on its Web site at: http://www.treas.gov/fincen/pub_main.html.

For no apparent reason, the policyowner has multiple life insurance policies under a single name or multiple names, or in the names of family members or corporate entities, or several policies purchased within a short period of time.

In conjunction with other indicia of money laundering, the policyowner requests that the life insurance policy's settlement proceeds be paid to ostensibly third parties unrelated to the policyowner.

The policyowner has acquired the life insurance policy in a prior settlement transaction and is a licensed settlement provider, but has only recently acquired the policy and does not appear to have a valid reason for reselling the policy.

The policyowner has acquired the life insurance policy in a prior settlement transaction, but the policyowner is not a licensed settlement provider, financing entity or related provider trust.

The policyowner has acquired multiple life insurance policies in prior settlement transactions, all or substantially all of which the policyowner acquired from residents of states that do not regulate viatical or life settlement transactions.

The policyowner requests that the life insurance policy's settlement proceeds be paid in currency other than U.S. currency.

The policyowner has borrowed the maximum cash value of a single premium life insurance policy soon after purchasing the policy.

Responding to Red Flags

If any representative of the Company detects any red flag, he or she shall promptly report it to the AML Compliance Officer who will investigate the matter further. The AML Compliance Officer, in consultation with General Counsel, will comply with all reporting obligations to the federal government regarding any criminal activity, including known terrorist financing or ongoing money laundering schemes, that are discovered in connection with any applications for the sale of a life insurance policy or settlement transactions effected with the Company.

Under the particular factual circumstances of a matter that does not involve known criminal activity, the AML Compliance Officer may, after consultation with General Counsel, determine that it is appropriate for the Company to voluntarily file a Suspicious Activity Report ("SAR") with the U.S. Treasury Department's Financial Crimes Enforcement Network ("FinCEN"). The Company is not required to and will not, however, file SARs to report false or fraudulent information used to obtain a life insurance policy or sell one in a settlement transaction, unless the Company has determined that the false or fraudulent information involves money laundering or terrorist financing. Notwithstanding the foregoing, because the Liability Safe Harbor provisions under the U.S.A. PATRIOT Act for the voluntary filing of SARs only apply to "Financial Institutions," which do not include life settlement broker companies, the Company should not make any voluntary SAR filing for any matter if the AML Compliance Officer determines, after consultation with General Counsel, that such SAR filing may, because of the inapplicability of such Liability Safe Harbor provisions, expose the Company to potential civil liability to the person or persons involved in such matter.

The AML Compliance Officer shall make a report of all SARs and other reports of criminal activity filed by the Company with the government to the Company's Manager annually or on such other more frequent periodic basis determined by the Company's Manager.

AML Records Retention Procedures

The AML Compliance Officer shall be responsible for ensuring that the Company's AML records are maintained properly. The Company will keep all SARs and any supporting documentation confidential and separate from other records to avoid inadvertent disclosure of SAR filings. Any documentation relevant to a customer's identity and verification and funds transfers and transmittals prepared for AML compliance purposes shall be kept for a period of at least five (5) years after the closing date of a settlement transaction.

Training Program

The AML Compliance Officer, in conjunction with the Company's senior management, will train those representatives who are in positions with the greatest likelihood for identifying possible indicia of money laundering in the procedures set forth in this Compliance Policy. All of the Company's representatives, however, will receive a copy of this Compliance Policy, and each representative whose job responsibilities include obtaining or reviewing information from or about life settlement customers must certify in writing that he/she has read and will comply with this policy.

Audit Program

The Audit Committee of the Company or its designees who are independent and not involved with the administration of the AML Program or under the supervision of the AML Compliance Officer shall conduct an annual audit of this Compliance Program. The audit may consist of a review of written documentation, interviews with employees and/or periodic testing of the effectiveness of the Compliance Program.