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.

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