Mr. Richard Dunston Malpass Mr. Richard Dunston Malpass (“Mr. Malpass”), resided in Thailand, solicited foreign investors to make investment in mutual fund based on his advice for the sake of tax

foreign investors to make investments according to Gilt Edge’s advice and management to earn tax benefits and long-term returns. Gilt Edge also advertised that the company had a team of professional and

investors to make investments according to Gilt Edge’s advice and management to earn tax benefits and long-term returns. Gilt Edge also advertised that the company had a team of professional and experienced

and management to earn tax benefits and long-term returns. Gilt Edge also advertised that the company had a team of professional and experienced experts to render financial knowledge and advice as well

securities business. EMM solicited a foreign resident by its financial and investment consultants to use its services and advice to transform his pension fund abroad into investment to gain tax benefits and

license from the SEC. EMM solicited a foreign resident by its financial and investment consultants to use its services and advice to transform his pension fund abroad into investment to gain tax benefits

from the SEC. EMM solicited a foreign resident by its financial and investment consultants to use its services and advice to transform his pension fund abroad into investment to gain tax benefits and

Mr. Neil Callard. Mr. Neil Callard. - as Account Manager, the representative office solicited the foreign investors to make investments according to Gilt Edge’s advice and management to earn tax