|SEVEN STARS CLOUD GROUP, INC. filed this Form 10-Q on 11/13/2017|
3.11 Compliance with U.S. Foreign Corrupt Practices Act and Other Applicable Anti-corruption Laws.
To the knowledge of the Company, the Company or any Subsidiaries or the directors, senior executives, agents or employees of the Company or any Subsidiaries (i) has (have) not used any funds for unlawful contribution, presents, gifts and entertainment or other unlawful expenses relating to political activities; (ii) has (have) neither provided any unlawful payment to any foreign or domestic governmental officials, staff, political parties and campaign, nor gone against with Foreign Corrupt Practices Act, 1977, as amended, and federal, foreign, state and other anti-corruption and anti-bribery laws or any similar Legal Requirements applicable to the Company or any Subsidiaries thereof. The Company and any Subsidiaries thereof has established corresponding guidelines, policies, procedures and control measures to ensure to observe various anti-corruption and anti-bribery laws or any similar Legal Requirements promulgated by U.S. federation, domestic and foreign
3.12 Internal Control.
(a) The Company and its Subsidiaries thereof have, in accordance with requirements of Exchange Act, implemented and maintained a complete set of internal control systems over financial reporting (as defined in Rule 13a-15(f) and 15d-15(f) of Exchange Act) which are capable of ensuring the reliability of financial reporting and that the financial statements are prepared as per GAAP for any external purposes.
(b) Upon the date when the Company files its latest financial statement with the SEC as per Form 10-K:
(i) there have not been any change in the internal control system for the financial reporting of the Company or its Subsidiaries thereof that is likely to have a significant impact on such internal control systems;
(ii) the Company has disclosed to external audit institution and Audit Committee of the Board all great defects and main disadvantages existing in design or operation in terms of internal control system of financial reporting and that may have adverse effect on the Company and any Subsidiaries thereof with respect to the ability of record, process, summary and reporting of various financial information;
(iii) the management or relevant employees that may have significant influence on the internal control system of financial statement of the Company and any Subsidiaries thereof have not been involved in any fraudulent conduct, whether such fraudulent conduct is material or not.