January 31, 2024

In an effort to combat tax evasion and fraud, money laundering, and the abuse of shell and front
companies by criminals, corrupt officials, and other bad actors doing business within the United States,
the Financial Crimes Enforcement Network (“FinCEN”), a division of the United States Department of
Treasury, seeks to create a database of personal information of each person who owns or has substantial
control over a business within the United States (a “Beneficial Owner”). Certain companies will have to file
a Beneficial Ownership Information Report (“BOI Report”) with FinCEN which will contain certain
identifying information about the Beneficial Owners of the company.

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