THE UNITED STATES VIRGIN ISLANDS OFFICE OF THE LIEUTENANT GOVERNOR DIVISION OF BANKING AND INSURANCE December 19, 2014 Erika Kellerhals, Esq. Kellerhals Ferguson Fletcher Kroblin LLP Attn: Financial Strategy Group, Ltd. No. 9100 Port of Sale Mall Suite 15, St. Thomas VI 00802 Re: Financial Strategy Group, Ltd. Dear Atty. Kellerhals: Enclosed are the Certificate of Licensure and Tax Incentive Benefit Certificate issued to Financial Strategy Group, Ltd., an International Banking Entity ("IBE") for calendar year 2015. These certificates are subject to the regulatory and administrative conditions in its Permit and as noted below: 1. The IBE license is effective on January 1, 2015 until the expiration thereof which shall be December 31st following the effective date, unless the same is suspended, revoked or renounced pursuant to Regulation 721-1(c). 2. A license to operate an IBE may not be sold, assigned, transferred, pledged, used as a security or in any other way encumbered , except under the provision of subsection 748 pursuant to 9V.I.C.§725. 3. The Tax Incentives Benefit Certificate is valid for a period of 10 years effective on January 1, 2015 until its expiration on December 31, 2015 or unless extended pursuant to 9 V.I.C. §744 or revoked, suspended or modified. Sincerely, r 77/0,hot-e90 J hn D. McDonald, irector, Division of Banking and Insurance EFTA01104787