Politically Exposed Persons (PEP) Identification Policy

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DGS DATA GOVERNANCE SYSTEMS LLC ("DGS") is committed to implementing robust measures to prevent financial crimes, including money laundering, corruption, and terrorist financing. As part of our compliance framework, we have established this Politically Exposed Persons (PEP) Identification Policy to mitigate risks associated with transactions involving individuals who may hold or have held prominent public positions.

This policy applies to all employees, clients, partners, and third parties engaged with DGS. It outlines the procedures to identify, assess, and monitor potential PEP relationships and ensure compliance with international regulations, including but not limited to:

• Financial Action Task Force (FATF) Recommendations
• U.S. Bank Secrecy Act (BSA) and FinCEN Guidelines
• European Union AML Directives
• Dominican Republic Law No. 155-17 on Money Laundering and Terrorism Financing

A Politically Exposed Person (PEP) is an individual who holds or has held a prominent public position, either domestically or internationally. This classification extends to their immediate family members and close associates. Examples include:

• Heads of state, government officials, ministers, and legislators
• Senior executives in state-owned enterprises
• High-ranking military officials
• Senior members of judicial, electoral, or financial regulatory bodies
• Close business associates or family members of the above categories

DGS adopts a risk-based approach to identify and assess PEP relationships. This includes:

1. Customer Due Diligence (CDD) – Mandatory verification of client identity, business activities, and potential political exposure.
2. Enhanced Due Diligence (EDD) – Additional scrutiny applied to individuals classified as PEPs, including:
   
   • Extensive background checks
   • Verification against global PEP databases and watchlists (FATF, OFAC, EU Sanctions Lists)
   • Detailed source of wealth and fund analysis

1. Ongoing Monitoring – Continuous transaction review to detect irregular patterns or suspicious activities involving PEPs.
2. Approval Procedures – High-risk relationships involving PEPs require approval from the Compliance Officer and Senior Management.

DGS reserves the right to decline or terminate business relationships if:

• The PEP is involved in corruption, bribery, or other financial crimes.
• The source of funds cannot be satisfactorily verified.
• There is a high risk of regulatory non-compliance or reputational damage.

To ensure compliance with global regulations, DGS:

• Maintains detailed records of PEP screenings and risk assessments for a minimum of five (5) years.
• Reports suspicious transactions or high-risk engagements to relevant authorities, including FinCEN, FATF, and local regulatory bodies.
• Ensures regular employee training on AML/PEP risk management.

This policy is subject to annual reviews to ensure alignment with international best practices and regulatory changes. Updates will be communicated to all relevant stakeholders.

For further inquiries, please contact the Compliance Office at DGS DATA GOVERNANCE SYSTEMS LLC.