DGS DATA GOVERNANCE SYSTEMS LLC ('DGS') is committed to maintaining the highest standards of integrity, transparency, and compliance with international regulations on Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT).

This policy establishes the principles, responsibilities, and procedures designed to explicitly prohibit and prevent any conduct or activity involving money laundering, asset laundering, or terrorism financing within our operations.

This policy applies to all employees, contractors, partners, and third parties associated with DGS. It is aligned with regulatory requirements in Puerto Rico and the Dominican Republic, as well as international standards such as the Financial Action Task Force (FATF/GAFI) recommendations and U.S. Bank Secrecy Act (BSA) regulations.

DGS ensures full compliance with AML/CFT regulations, including but not limited to:
Puerto Rico: Compliance with U.S. Department of the Treasury (FinCEN) regulations and Bank Secrecy Act (BSA) provisions.
Dominican Republic: Adherence to Law No. 155-17 on Money Laundering and Terrorist Financing and regulations issued by the Superintendence of Banks.

Global Standards: Compliance with the FATF recommendations and best practices from the OECD and the United Nations Office on Drugs and Crime (UNODC).

DGS adopts a risk-based approach (RBA) to AML/CFT compliance, including:
- Conducting Know Your Customer (KYC) and Know Your Business (KYB) due diligence before entering into business relationships.
- Assessing risks related to transactions, client profiles, and business operations.
- Implementing enhanced due diligence (EDD) for high-risk clients and transactions.

DGS explicitly prohibits any conduct or activity that involves money laundering, asset laundering, or financing of terrorism. 

All employees, contractors, and third-party partners acknowledge and accept this commitment and must comply with this policy and applicable AML/CFT laws and regulations.

DGS employs strong internal controls to prevent and detect suspicious activities:

· Transaction Monitoring: Regular review of financial transactions to identify unusual or high-risk patterns.

· Record-Keeping: Maintaining detailed records of all financial transactions, client due diligence processes, and compliance actions for at least five (5) years.

· Whistleblower Mechanism: Providing confidential and anonymous reporting channels accessible to employees, suppliers, and the general public to report suspicious activities without fear of retaliation. Available at https://dgs-online.com/ethics-reporting. 

To ensure compliance and awareness across the organization, DGS provides mandatory AML/CFT training to all key employees and relevant third parties, covering:
 

· Identification of money laundering and terrorist financing risks

· Regulatory obligations and legal consequences of non-compliance.

· Procedures for reporting suspicious transactions.

The training also includes communication of relevant internal policies and documents, ensuring all employees and partners understand their responsibilities.

DGS is committed to cooperating with regulatory authorities and will report any suspicious transactions (STRs) to the relevant Financial Intelligence Units (FIUs):

· Puerto Rico: Financial Crimes Enforcement Network (FinCEN)

· Dominican Republic: Financial Analysis Unit (UAF)

DGS is committed to conducting periodic internal and external audits, independent evaluations, and compliance reviews to assess the effectiveness of this Policy and to identify areas for improvement. These measures ensure our AML/CFT program remains robust, up-to-date, and aligned with legal and regulatory requirements.

Failure to comply with AML/CFT regulations and this Policy may result in:
- Disciplinary action, including termination of employment or contracts.
- Legal consequences, including regulatory penalties.
- Reputational risks for both the employee and the company.

This Policy complements and integrates with the DGS Code of Ethics, Anti-Corruption Policy, and other relevant policies, forming a holistic compliance framework.

This policy will be reviewed and updated annually or as required by regulatory changes to ensure continued compliance and effectiveness.

DGS DATA GOVERNANCE SYSTEMS LLC enforces this AML/CFT policy to uphold its commitment to ethical business practices and regulatory compliance, ensuring a secure and compliant operational environment for all stakeholders.

Effective Date: June 4, 2025

For any questions or concerns about this policy, please contact the Compliance Department at compliance@dgs-online.com.