COMPLIANCE POLICY
1. PURPOSE
This Policy defines the Company’s compliance framework ensuring adherence to:
- laws of Saint Lucia;
- international financial regulations;
- internal procedures.
2. GOVERNANCE STRUCTURE
The Company operates under a Sole Director model.
The Director:
- approves policies;
- oversees compliance;
- appoints MLRO / Compliance Officer.
3. COMPLIANCE FUNCTION
The Compliance function ensures:
- regulatory compliance;
- internal monitoring;
- risk mitigation.
4. ROLE OF COMPLIANCE OFFICER
Responsibilities:
- monitor compliance;
- review procedures;
- report risks;
- ensure AML implementation.
5. INTERNAL CONTROLS
The Company implements:
- control procedures;
- audit mechanisms;
- approval workflows.
6. MONITORING & AUDIT
Includes:
- internal audits;
- compliance checks;
- periodic reviews.
7. EMPLOYEE TRAINING
Mandatory training includes:
- AML awareness;
- fraud detection;
- sanctions.
8. THIRD-PARTY COMPLIANCE
All partners:
- undergo due diligence;
- are required to comply with applicable requirements.
9. RISK MANAGEMENT
The Company manages:
- operational risks;
- compliance risks;
- financial crime risks.
10. INCIDENT MANAGEMENT
Includes:
- reporting violations;
- internal investigations;
- corrective actions.
11. RECORD KEEPING
Compliance records are maintained securely.
12. POLICY REVIEW
Reviewed regularly by Director.