ANTI-MONEY LAUNDERING (AML) AND COUNTER-TERRORISM FINANCING

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1. Purpose
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 prevent and detect money laundering and terrorism financing activities within our operations.

2. Scope
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.

3. Regulatory Compliance
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).

4. Risk Assessment and Due Diligence
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.

5. Monitoring and Internal Controls
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 reporting channels for employees to report suspicious activities.

6. Employee Training and Awareness
To ensure compliance and awareness across the organization, DGS provides mandatory AML/CFT training to all key employees, covering:

• Identification of money laundering and terrorist financing risks.
• Regulatory obligations and legal consequences of non-compliance.
• Procedures for reporting suspicious transactions.

7. Reporting Obligations
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)

8. Non-Compliance and Disciplinary Actions
Failure to comply with AML/CFT regulations may result in:

• Disciplinary action, including termination of employment.
• Legal consequences, including regulatory penalties.
• Reputational risks for both the employee and the company.

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

Commitment Statement:
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: (01/01/2023) 

End of Policy Document