Nordea Investment Management North America, Inc.

Event Detail: COUNT 1 - MISDEMEANOR - FAILURE TO INVESTIGATE AND REPORT SUSPICIOUS TRANSACTIONS IN IB. COUNT 2 - MISDEMEANOR - THE CUSTOMERS IN THE ROMANOV GROUP - KYC - FAILURE TO INVESTIGATE TRANSACTIONS AND FAILURE TO NOTIFY THE AML SECRETARIAT. COUNT 3 - MISDEMEANOR - THE FOREIGN EXCHANGE OFFICES - INVESTIGATION OF SUSPICIOUS TRANSACTIONS. COUNT 4 - MISDEMEANOR - BULK CANCELLATION OF ALARMS - CORRESPONDENT BANKING RELATIONSHIPS - FAILURE TO MONITOR TRANSACTIONS. ALL COUNTS ARE RELATED TO BANKING ACTIVITIES. Status: Pending Disposition: PENDING COURT DATE Summary: NORDEA IS ACCUSED OF NOT HAVING HAD ADEQUATE ANTI-MONEY LAUNDERING CONTROLS IN THE PERIOD DATING BACK TO 2015 AND EARLIER. FOLLOWING INVESTIGATIONS CONDUCTED BY THE AUTHORITIES INTO ANTI-MONEY LAUNDERING CONTROLS IN THE PERIOD DATING BACK TO 2015 AND EARLIER, THE DANISH STATE PROSECUTOR FOR SPECIAL CRIME (NSK), HAS ANNOUNCED THAT IT WILL COMMENCE COURT PROCEEDINGS. NORDEA BANK ABP DOES NOT AGREE WITH THE LEGAL ASSESSMENT MADE BY THE AUTHORITIES.

Allegations: FINANSINSPEKTIONEN ALLEGED THAT NORDEA INVESTMENT MANAGEMENT AB WAS LATE WITH A MONTHLY REPORTING OF CAPITAL ADEQUACY. THE FULL CAPITAL ADEQUACY REPORT IS DUE QUARTERLY. THIS LATE FILING REFERS TO A MONTHLY QUOTA REPORT. THE CAPITAL ADEQUACY QUOTA WAS DUE ON SEPTEMBER 30, 2013 AND WAS FILED ON OCTOBER 1, 2013. Status: Final Sanction Detail: SEK 20,000 FINE Summary: NORDEA INVESTMENT MANAGEMENT AB RECEIVED AN ADMINISTRATIVE FINE OF SEK 20,000.

Allegations: FINANSINSPEKTIONEN ALLEGES THAT NORDEA BANK AB HAD DEFICIENCIES IN GOVERNANCE AND INTERNAL CONTROLS RELATED TO ANTI-MONEY LAUNDERING REGULATIONS. ADDITIONAL ALLEGATIONS INCLUDE FAILURE TO SCREEN BENEFICIAL OWNERS AGAINST EU SANCTION REGULATIONS, DEFICIENCIES IN REPORTING TRANSACTIONS IN FROZEN ACCOUNTS, AND A SINGLE INSTANCE OF DEFICIENCY IN CUSTOMER DUE DILIGENCE PROCEDURES RELATED TO A CUSTOMER. THESE ISSUES RELATE SPECIFICALLY TO BANKING OPERATIONS IN SWEDEN AND ARE NOT RELATED TO INVESTMENT MANAGEMENT ENTITIES OR OPERATIONS. Status: Final Sanction Detail: 30,000,000 SEK FINE Summary: NORDEA BANK AB RECEIVED A REMARK FROM FINANSINSPEKTIONEN AND PAID AN ADMINISTRATIVE FINE OF 30 MILLION SWEDISH KRONOR.

Allegations: THE DANISH FSA ALLEGED THAT NORDEA INVESTMENT MANAGEMENT AB FAILED TO REPORT 913 TRANSACTIONS FROM 2007 TO JANUARY 2015. Status: Final Sanction Detail: ADMINISTRATIVE FINE OF DKK 20,000. Summary: THE DANISH FSA FINED NORDEA INVESTMENT MANAGEMENT AB DKK 20,000. THE FINE WAS FOR PAST REPORTING ISSUES AND THE ISSUE HAS BEEN CORRECTED.

Allegations: FINANSINSPEKTIONEN ALLEGES THAT NORDEA BANK AB HAS HAD FLAWS IN EFFORTS TO COMBAT MONEY LAUNDERING. THE SHORTCOMINGS HAVE BEEN SIGNIFICANT AND SYSTEMATIC IN NATURE. FI ALLEGES THAT AS A RESULT NORDEA HAS ALSO BREACHED ITS DUTY TO MAINTAIN ADEQUATE INTERNAL CONTROL. THE ALLEGATIONS ARE FOR NORDEA BANK AB AND NOT FOR THE ASSET MANAGEMENT PART OF THE ORGANIZATION. Status: Final Sanction Detail: NORDEA BANK AB HAS RECEIVED A WARNING ALONG WITH A SEK 50M FINE. Summary: FINANSINSPEKTIONEN HAS STATED THAT NORDEA HAS A COMPREHENSIVE ACTION PLAN WHICH DEMONSTRATES THAT NORDEA HAS REALIZED THE EXTENT OF THE PROBLEMS AND HAS A DESIRE TO CORRECT THE DEFICIENCIES AND THAT NORDEA INTENDS TO PROVIDE THE COMPLIANCE FUNCTION WITH FURTHER RESOURCES AND THE ASSIGNMENT TO MONITOR AND FOLLOW UP ON THE IMPLEMENTATION OF THE ACTION PLAN. THE SFSA'S ASSESSMENT IS THAT THE FORECAST FOR THE BANK IS GOOD AND THE SFSA THEREFORE FINDS IT SUFFICIENT TO ISSUE NORDEA A WARNING TOGETHER WITH AN ADMINISTRATIVE FINE OF SEK 50 MILLION.

Allegations: THE FIN-FSA HAS IMPOSED THE FOLLOWING ADMINISTRATIVE SANCTIONS ON NORDEA BANK AB (PUBL), FINNISH BRANCH: A PENALTY PAYMENT OF EUR 1,000,000 AND A PUBLIC WARNING. FIN-FSA CONDUCTED AN INSPECTION AT NORDEA BANK FINLAND PLC IN 2015-2016 REGARDING THE OBLIGATION TO OBTAIN INFORMATION IN CONNECTION WITH INVESTMENT ADVICE PROVIDED BY THE BANK. THE INSPECTION FOCUSED ON EXAMINING HOW INVESTMENT FUND PRODUCTS AND STRUCTURED FINANCIAL INSTRUMENTS HAD BEEN SOLD TO NON-PROFESSIONAL CUSTOMERS AGED OVER 70. THE INSPECTION IDENTIFIED SEVERAL CASES OF NON-COMPLIANCE WITH THE PROVISIONS OF THE INVESTMENT SERVICES ACT AND THE REGULATIONS ISSUED BY THE FIN-FSA. Status: Final Sanction Detail: 1,000,000 EUR (CONVERSION RATE $$1.057) ON MARCH 7, 2017. Summary: THE PUBLIC WARNING WAS ISSUED FOR NON-COMPLIANCE WITH THE OBLIGATION TO OBTAIN INFORMATION AND NON-COMPLIANCE WITH THE SUITABILITY ASSESSMENTS. THE PENALTY PAYMENT, IN TURN, WAS IMPOSED FOR OMISSIONS REGARDING DOCUMENTATION REQUIREMENTS AND FOR FAILURE TO IDENTIFY AND PREVENT CONFLICTS OF INTEREST.

Allegations: FINANSTILSYNET ALLEGES THAT RESULTING FROM AN INSPECTION ON TRANSACTION MONITORING THERE WERE A NUMBER OF FINDINGS WHICH GAVE RISE TO SUPERVISORY RESPONSES. THESE RELATED TO COVERAGE OF TRANSACTIONS, SUFFICIENT MONITORING OF SPECIFIC BUSINESS AREAS, SCENARIOS AROUND CUSTOMER BEHAVIOR, BUSINESS PROCEDURES AND THE MONITORING SYSTEMS MODEL FOR AUTOMATIC SCORING. THESE FINDINGS RELATE SOLELY TO BANKING OPERATIONS IN DENMARK AND ARE NOT RELATED TO INVESTMENT MANAGEMENT ENTITIES OR OPERATIONS. Status: Final Sanction Detail: FINANSTILSYNET ISSUED SUPERVISORY RESPONSES RESULTING IN FIVE ORDERS TO FURTHER ENHANCE TRANSACTION MONITORING. Summary: NORDEA BANK ABP, DENMARK BRANCH RECEIVED FIVE ORDERS IN THE AREAS OF TRANSACTION MONITORING. SYSTEMS AND MONITORING ARE BEING UPDATED TO ADDRESS THE ORDERS.

Allegations: ON THE 21 FEBRUARY 2022 EUREX DEUTSCHLAND ISSUED A REPRIMAND TO NORDEA BANK ABP DUE TO THE LATE CONFIRMATION OF A TOTAL OF FOUR T7 ENTRY SERVICE TRANSACTIONS WHEREBY THE DEADLINE OF CONFIRMING WITHIN 15 MINUTES WAS EXCEEDED. THIS WAS A VIOLATION AGAINST CLAUSE 4.4. PARA. 2 OF THE TRADING CONDITIONS. Status: Final Sanction Detail: A PROCEDURAL FEE WAS SET AT EUR 1000.00 (CONVERSION RATE 1.10) Summary: EUREX REPRIMANDED NORDEA BANK ABP FOR FAILURE TO CONFIRM FOUR T7 ENTRY SERVICE TRANSACTIONS WITHIN THE STIPULATED 15 MINUTES AND IMPOSED A PROCEDURAL FEE OF EUR 1,000.

Allegations: NFSA PUBLISHED THE FINAL REPORT FROM THE 2020 ON-SITE INSPECTION ON AML AND CTF WHERE THEY IDENTIFIED DEFICIENCIES RELATED TO ROUTINES/PROCEDURES, ENHANCED DUE DILIGENCE MEASURES AND TRADE FINANCE. Status: Final Sanction Detail: NFSA ISSUED THREE ORDERS RELATED TO ROUTINES/PROCEDURES, ENHANCED DUE DILIGENCE MEASURES AND TRADE FINANCE. FURTHER TO THE ORDERS, UNSPECIFIED SANCTIONS IF THE REMEDIATION DEADLINE 02/28/2023 IS NOT MET. Summary: RESPONSE TO NFSA SEND 02/28/2023 CONFIRMING CLOSURE OF ALL THREE ORDERS

Allegations: NORDEA FAILED TO MAINTAIN AN EFFECTIVE AND COMPLIANT ANTI-MONEY LAUNDERING PROGRAM, IN VIOLATION OF 3 N.Y.C.R.R. § 116.2. NORDEA FAILED TO CONDUCT ADEQUATE DUE DILIGENCE IN ITS CORRESPONDENT BANK AND RMA RELATIONSHIPS IN VIOLATION OF 3 N.Y.C.R.R. § 116.2. NORDEA FAILED TO MAINTAIN AN ADEQUATE TRANSACTION MONITORING SYSTEM IN VIOLATION OF 3 N.Y.C.R.R. § 504.3. Status: Final Sanction Detail: NORDEA SHALL PAY A CIVIL MONETARY PENALTY PURSUANT TO BANKING LAW §§ 39 AND 44 TO THE NYDFS IN THE AMOUNT OF THIRTY-FIVE MILLION U.S. DOLLARS ($35,000,000.00) WITHIN TEN (10) DAYS OF EXECUTING THIS CONSENT ORDER. THE FINE WAS PAID ON AUGUST 27, 2024. Summary: NORDEA REACHED A RESOLUTION WITH THE NYDFS FOLLOWING AND INVESTIGATION RELATED TO THE ADEQUACY OF NORDEA'S AML PROGRAM DURING THE PERIOD 2008 TO 2019. THE HISTORICAL INVESTIGATION BY THE NYDFS CONCERNED NORDEA'S FORMER PROCESSES, POLICIES, AND CONTROL TO PREVENT MONEY LAUNDERING. NORDEA FAILED TO MAINTAIN AN EFFECTIVE AND COMPLIANT ANTI-MONEY LAUNDERING PROGRAM, IN VIOLATION OF 3 N.Y.C.R.R. § 116.2. NORDEA FAILED TO CONDUCT ADEQUATE DUE DILIGENCE IN ITS CORRESPONDENT BANK AND RMA RELATIONSHIPS IN VIOLATION OF 3 N.Y.C.R.R. § 116.2. NORDEA FAILED TO MAINTAIN AN ADEQUATE TRANSACTION MONITORING SYSTEM IN VIOLATION OF 3 N.Y.C.R.R. § 504.3. NORDEA BANK ABP, INCLUDING THE NY BRANCH, AGREED TO THE ORDER AND PAID THE FINE ON AUGUST 27, 2024. NO FURTHER ACTION WILL BE TAKEN BY THE NY STATE DEPARTMENT OF FINANCIAL SERVICES AGAINST NORDEA BANK ABP AND ITS NEW YORK BRANCH FOR THE CONDUCT SET FORTH IN THE CONSENT ORDER.