Appleby Trust (Isle of Man) Limited Form Type: New Business File Note Ref: Form 1 Pages: Page 1 of 5 Date: Client: Name: Ibrahim Mahama CEO of Engineers and Planners, in Ghana Address: Ghana Contact Details: Adi Ayitevie Introducer: Name: Lous Kamisky, American Aircraft Marketing Address: Contact Detailsare providing services to: Initial new Please circle Low/medium/high business risk Source of wealth will be generated through assessment though-t mining in high risk countries (Formal . UBO is the brother of the Ghana president CRA not Aircraft ownership and operation and dry leasing. required at this stage): Client Background Set out in details background on the client, source of wealth, and include results of any internet research conducted. Engineers Planners is Ghana?s leading mining contracting firm that provides mine support services to the Extractive Industry particularly Gold and Iron Ore mining companies in Ghana. With its headquarters in Ghana and other of?ces in Liberia, Engineers Planners started its operations in 1997, renting Heavy Duty Equipment to companies in the Construction and Extractive Industries. Today, our interests have been diversi?ed in terms of geographical location and services delivery. Our core business encompasses mining, exploration grade control, load and haul, bulk haulage transport, earth civil works, heavy duty equipment rental as well as to provide consultancy services to the extractive industry. OBJECTIVES 0 To promote value-based sustainable organisational development for high performance in our business. 0 To be socially responsible and promote the interest of our stakeholders 0 To promote safety and best environmental practices Appleby Trust (Isle of Man) Limited Form Type: Ref: Pages:  New Business File Note Form 1 Page 2 of 5 To provide sustainable economic empowerment of people in our operational communities and countries. Engineers and Planners also own MBG Ltd which are Ghana’s largest supplier of MAN trucks. There are various reports and allegations concerning non repayment of a $50m loan taken by the company from Merchant Bank and that the debt was being serviced by diverting government funds. Background Set out in detail any known background to the structure including details on all parties and include results of any research conducted. The client is purchasing an Aircraft from CS Aviation, they are intending to purchase a Challenger 604 (2001) with a value of USD 7,000,000. They currently own a Challenger 600 from the information that we have located on the internet. The aircraft is being sold by Hapag-Lloyd a large shipping company. They have a number of aircraft within their aviation division. Proposed Structure Set out in detail the proposed structure and its purpose, expected assets, turnover, areas of operation, the advice on which is based (ie tax advice), any funding arrangements, any business plans, etc. The new Isle of Man Company will be owned by corporate entity of which we are yet to receive full details. This entity is wholly owned by Ibrahim Mahama (we believe). The aircraft will be operated by Engineers & Planners in Ghana. Services to be provided Set out details of the services to be provided by ATIOML - Provision of a shelf company Director RA RO On-going admin Importation of Aircraft Will ATIOML be compiling accounts ? Are we opening bank account for company and providing authorised signatories.? Appleby Trust (Isle of Man) Limited Form Type: Ref: Pages: New Business File Note Form 1 Page 3 of 5 Due Diligence Held Set out below and attach details of all CDD held or requested. Due Diligence has been requested FATCA1 Due Diligence – on any parties connected to the structure these questions must be answered 1. Are there any US residents/citizens connected to the client - NO 2. Are we to use or have on file a US residence or mailing address - NO 3. A US place of birth - NO 4. Are we to use or have on file a US ‘ in care of ‘ address (PO Box addresses are not allowed to be used – but check in case of a business address) - NO 5. Are there powers of attorney or signatories appointed with an associated US address - NO 6. Are we to have any standing instructions to transfer funds to a US account - NO 7. Are there any US telephone numbers - NO 8. Does the client hold any assets in the US - NO Other Business & Risk factors 1 Aircraft will operate in Ghana The UBO is the brother of the President of Ghana (bribery/corruption are a risk) Allegations linking the President to the previous purchase of an aircraft however The US foreign account tax compliance act (FATCA) was introduced Oct 2009. The FATCA regime falls on Foreign Financial Institutions (FFIs). It requires FFIs to provide the Internal Revenue Service (IRS) with information on certain U.S. persons. The FFI needs to identify an account has having any of the U.S. indicia in the above section Appleby Trust (Isle of Man) Limited Form Type: Ref: Pages: - New Business File Note Form 1 Page 4 of 5 these were denied Engineers & Planners operate in Liberia, and looking to expand into the Democratic Republic of Congo and Republic of Guinea all of which are considered higher risk jurisdictions and all subject to international sanctions. Fees Set out details of the proposed fees. Are any fees required in advance? 3,750 Set up 1,500 Dry Lease 2,000 Registration 6,000 Responsibility 6,000 WIP Issued by Allister Crossley Date New Business Administrator or Senior Manager Recommendations and Comments of the New Business Committee Authorised to proceed: Conditions: Yes/No - Confirmation of source of funds, particularly in view of alledged non repayment of loan to company. - Full CDD (enhanced level due to categorisation) - Add to PEP register due to family link to the Ghana President. - Consider the reputational aspects of being associated with the transaction. Follow up required Yes/No within 1 month: Timeframe for follow up if less than 1 month: Approved Date Appleby Trust (Isle of Man) Limited Form Type: Ref: Pages: Sponsoring Partner or Executive Partner: Compliance: D G Bone New Business File Note Form 1 Page 5 of 5