Risk Management and Compliance Programme
Risk Management and Compliance Programme (RMCP)
Table of Contents:
Overview
Definitions and Concepts
RMCP Governance
Risk-Based Approach
Client Due Diligence (CDD) Controls
Politically Exposed and Prominent Influential Persons
Terrorist and Proliferation Financing
Client Account Monitoring
Reporting
Record Keeping
ANNEXURE A: Risk Matrix
ANNEXURE B: CDD Requirements
ANNEXURE C: Suspicious Transactions
1. Overview
1.1. The entity referred to as the "Company" (as defined in paragraph 2) has developed this RMCP to establish clear procedures for the Company and its employees to comply with.
1.2. The RMCP accordingly represents the apex document of the Company through which it establishes a consolidated and overarching Compliance Framework together with the accompanying procedures and policies.
1.3. Without affecting the primary status of this RMCP, employees should take note of other documents, guides, and manuals of the Company. In the event of any conflict between the provisions of this RMCP and any other Company document relating to any obligation and/or requirement, this RMCP will take precedence.
2. Definitions and Concepts
2.1. Definitions
In this document, unless the context otherwise requires, the following bolded/capitalised terms shall have the meanings assigned to them below.
| Term | Definition |
|---|---|
"Beneficial Owner” | is defined as a natural person who directly or indirectly ultimately owns or exercises effective control. |
“CDD” | means client due diligence and identity verification. |
“Clients” | means any person or entity that enters into a relationship with the Company and/or uses the services of the Company. |
“Company” | means Dark Fusion Holdings, a company duly incorporated in accordance with the company laws of Luxembourg. |
"Compliance Framework” | the risk management and compliance framework of the Company as established by this RMCP, aimed at promoting and ensuring compliance by the Company with its obligations. |
"Compliance Officer” | the designated officer of the Company. |
"Compliance Team” | the team responsible for the Compliance Framework. |
"Employee(s)” | all professionals and support staff members of the Company who are under an obligation to comply with the provisions of the RMCP when engaging with a Client. |
“AML Training” | training provided to Employees of the Company in relation to Client Due Diligence, reportable transactions. |
“ML/TF/PF” | abbreviations for Money Laundering (ML), Terrorist Financing (TF), Proliferation Financing (PF). |
"Ongoing CDD” | ongoing CDD in respect of Clients as contemplated in RMCP. |
“PEP” | a domestic or foreign politically exposed person. |
“PIP” | a prominent influential person. |
“Risk-Based Approach” | has the meaning ascribed thereto in RMCP. |
“Risk Matrix” | the risk assessment scoring framework of the Company as contained in Annexure ‘A’ used to risk rate the inherent ML/TF/PF risks associated with Clients and/or transactions. |
“RMCP” | the risk management and compliance programme of the Company as contained in this document, setting out its obligations and compliance requirements, as well as all relevant and required procedures, time frames and obligations of the Company. |
“Senior Management” | refers to the Management of the Company, who is elected from time to time by the board of directors of the Company. |
2.2. Key Concepts
2.2.1. Risk-Based Approach
2.2.1.1. The Company takes a Risk-based approach to identifying, monitoring, mitigating, and managing ML/TF/PF risks where client risk assessment is continuously applied in all the business processes, controls, and preventative measures of the Company.
2.2.1.2. The Company makes use of a risk matrix tool to provide an objective basis for the assessment of ML/TF/PF risks using risk indicators relevant to the Company. Each risk indicator should be risk weighted to enable an overall calculation and rating of the ML/TF/PF risk in respect of a client and so provide a Risk-based approach to assessing the inherent ML/TF/PF risk in engaging a client.
2.2.2 Money Laundering
2.2.2.1. Money laundering and its related activities is recognised as an activity which has or is likely to have the effect of disguising or concealing the nature, source, location disposition or movement of the proceeds of unlawful activities or any interest which any person or entity has in such proceeds.
2.2.3. Terrorist and Related Activities
Terrorist and related activities are defined as being any conduct or activity related to or connected with the commission of the offence of terrorism, or an offence related to or connected with a terrorist activity, or an international convention offence.
2.2.4. Proliferation Financing
Proliferation Financing is an activity which has or is likely to have the effect of providing property, a financial or other service or economic support to a non-State actor, and that may be used to finance the manufacture, acquisition, possessing. development, transport, transfer, or use of nuclear, chemical, or biological weapons and their means of delivery.
2.2.5. Beneficial Owner
2.2.5.1. Beneficial Owner is defined as a natural person who directly or indirectly ultimately owns or exercises effective control:
2.2.5.1.1. of a Client; or
2.2.5.1.2. of a legal person, partnership or trust that owns or exercises effective control of a Client.
2.2.5.2. Included in the above is a natural person who exercises control of a Client on whose behalf they are entering into a relationship with the Company.
2.2.5.3. When applying this definition in respect of a legal person, the Beneficial Owner(s) shall be identified by applying the following phased approach:
2.2.5.3.1. Identifying each natural person who has a controlling ownership interest in the legal person by holding 25% or more shares/membership in the legal person.
2.2.5.3.2. If there is doubt as to whether the persons with such controlling ownership interests are indeed the Beneficial Owners or where no natural person has a controlling ownership interest, the identity of the natural person who exercises control of the legal person through other means, including through ownership or control of other legal persons, partnerships or trusts or by acting together with another person to obtain a controlling interest, should be identified to the extent reasonably possible. In this instance, the Company must request such reasonable additional CDD documents as may be necessary to identify the natural person(s) exercising control.
2.2.5.3.3. If a natural person cannot be identified, the identity of the relevant natural person who exercises control over the management of the legal person, including in capacity such as senior managing official, chief financial officer, independent non-executive director, or chief executive officer, should be identified to the extent reasonably possible.
2.2.5.4. When applying this definition in respect of a partnership, the Beneficial Owner(s) would be every partner, including members of an en commandite partnership, and in the case that a partner is a legal person, or a natural person acting on behalf of a partnership or trust, the Beneficial Owner of such legal person, partnership, or trust. In addition, the Company must establish the identity of the natural person(s) who exercise(s) executive control of the partnership and of each natural person authorised to enter a relationship with the Company.
2.2.5.5. When applying this definition in respect of a trust, the Beneficial Owners would include the founder, the trustees and the beneficiaries of the trust as identified in the trust instrument:
2.2.5.5.1. It a founder of a trust is a legal person or a person acting on behalf of a partnership or trust, the Beneficial Owners of such legal person, partnership or trust would need to be established.
2.2.5.5.2. If a trustee is a legal person or a person acting on behalf of a partnership, the Beneficial Owners of such legal person or partnership would need to be established as well as each natural person authorised to enter into a relationship with the Company whether such persons is appointed as a trustee of the trust or not.
2.2.5.5.3. In respect of the beneficiaries of the trust, the identity of each named beneficiary in the trust instrument must be established, and where the beneficiary so referred to by name is a legal person, or a natural person acting on behalf of a partnership or trust, the Beneficial Owner of such legal person, partnership or trust must be established. Where the beneficiaries are not referred to by name in the trust instrument, the particulars of how beneficiaries of the trust are determined must be established.
3. RMCP Governance
3.1. Governance Structures
3.1.1. Board of Directors
The Board of Directors of the Company bears ultimate responsibility for compliance with the RMCP and its compliance obligations.
3.1.2. Senior Management
3.1.2.1. Senior Management has been mandated by the Board of Directors of the Company with responsibility for the day-to-day management and compliance of the Company with the RMCP.
3.1.2.2. It is the responsibility of Senior Management to review the RMCP and propose changes thereto if required by operational requirements or legislative amendments, as well as to approve or reject the acceptance of high-risk clients by the Company.
3.1.3. Compliance Officer
The Compliance Officer of the Company is officially appointed by the Company in that capacity and is provided with a Compliance Team in order to ensure that the Company follows the processes and procedures set out in the RMCP and for the Company to meet its compliance obligations.
3.2. RMCP Approval
The RMCP of the Company (including all amendments thereto from time to time) has been approved by Senior Management.
3.3. RMCP Review
This RMCP will be reviewed by Senior Management and updated (if necessary):
3.3.1. At least annually.
3.3.2. Where there is a material change to any processes or compliance obligations.
3.3.3. Where there is a relevant legislative change, then within 2 (two) months of such amendment coming into effect, unless an earlier period is expressly required in terms of such legislation or advisory.
3.4. Applicability
This RMCP applies to all employees of the Company and is made available to all employees via the intranet/network of the Company. The RMCP is also available upon request from the Compliance Officer.
3.5. Training
Training will be conducted by the Compliance Officer on the RMCP to all employees of the Company.
3.5.1. Training will be provided at the following's intervals on an ongoing basis:
3.5.1.1. Annually for all employees
3.5.1.2. Without delay following any substantial amendment of the RMCP and which requires staff training.
3.5.1.3. At the commencement of employment of new employee
3.6. Non-compliance with RMCP or Compliance Obligations
3.6.1. Employees are required to inform the Compliance Officer without delay of any incidence of non-compliance with the RMCP and the Compliance Officer must address any non-material instances immediately to rectify the non-compliance.
3.6.2. The Compliance Officer must escalate any material instance of non-compliance with the RMCP to Senior Management immediately upon becoming aware thereof.
3.6.3. Senior Management must assess the degree of non-compliance and make a determination in this regard, as well as the possible consequences and corrective measures the Compliance Officer must implement.
3.6.4. The following general corrective measures must apply to any event of material non-compliance:
3.6.4.1. The non-compliance and circumstances that gave rise thereto must be investigated by the Compliance Officer and reported to Senior Management.
3.6.4.2. All reasonable corrective steps must be taken to ensure that such non-compliance does not occur again in future, which may include but are not limited to:
3.6.4.2.1. Amendments to the RMCP;
3.6.4.2.2. Additional training and/or guidance and/or
3.6.4.2.3. Disciplinary action.
3.6.5. Without derogating from the above, it is recorded that in line with the Risk-based approach adopted by the Company, Senior Management may endorse, approve, or otherwise excuse any non-compliance with the provisions of this RMCP.
4. Risk-Based Approach
4.1. Company Services
Certain services rendered by the Company have been recognised as vulnerable to abuse for the laundering of the proceeds of crimes. Accordingly, the services provided by the Company have been included in the Risk Matrix and weighted according to their potential vulnerability and risk for abuse.
4.2. Risk Rating Methodology
4.2.1. The Company follows a Risk-based approach with its Clients. This implies that the risk in relation to a Client and transaction be rated using the Risk Matrix to establish the Inherent ML/TF/PF risk in engaging a Client or undertaking a specific transaction.
4.2.2. The Risk Matrix has been developed by assessing the various services and other risk indicators deemed relevant to the Company in assessing its ML/TF/PF risks. Each risk indicator has been weighted according to its perceived risk.
4.2.3. When conducting a risk assessment on a Client the Risk Matrix must be used to obtain a risk rating using the risk indicators and their respective weightings. Based on the weightings of risk indicators found applicable, the final score will determine whether the Client and/or transaction is:
4.2.3.1. Low Risk;
4.2.3.2. Medium Risk; or
4.2.3.3. High Risk.
and which risk rating will determine the applicable consequences as set out in this RMCP.
4.2.4. Understanding that the ML/TF/PF risks are susceptible to change, the Company will at least annually review the appropriateness and weighting of each risk indicator and where necessary make changes to the Risk Matrix to reflect the Company's current view of its inherent ML/TF/PF risks.
4.2.5. The Company must also evaluate the inherent ML/TF/PF risks relating to any new product or service introduced by the Company and update the Risk Matrix accordingly to accommodate such new product or service.
4.3. Risk Matrix
4.3.1. The Risk Matrix used by the Company includes a number of risk indicators that determine the level of risk associated with a Client. These risk indicators relate to:
4.3.1.1. The type of Client, for example is the Client a natural person or an entity.
4.3.1.2. The type of service that the Company will render to the Client.
4.3.1.3. The location of the Client.
4.3.1.4. The channel through which the Client was engaged, for example was the Client engaged on a face-to-face basis or referred via an intermediary.
4.3.1.5. The occupation of the Client, for example is the Client a self employed or merely an employee.
4.3.1.6. The sector in which the Client's main business activities are conducted, for example is the client active in the financial services industry or in the gambling industry.
4.3.1.7. Is the Client a prominent exposed or influential person, for example a PEP or PIP.
4.3.1.8. Is there adverse media in relation to the Client, for example news articles or reports identifying the Client as being linked to corruption.
4.3.1.9. Is the Client listed on a relevant sanctions list.
4.3.1.10. What is the main source of funds for the Client's transaction, for example is it employee renumeration or trust distribution.
4.3.1.11. What is the size of the transaction.
4.3.1.12. is there suspicious conduct or behaviour by the Client?
4.3.1.13. Is there an unusual level of Cash involved in the transaction?
4.3.1.14. What type of cryptocurrency or token is being used by the Client?
4.3.1.15. Are there any related parties to the Client that are potentially high risk?
4.3.2. The above risk indicator examples are not a comprehensive list of options available for each risk indicator type. A comprehensive list of options form part of the Risk Matrix with each option weighted for its inherent risk.
4.4. Risk Assessment
4.4.1. The Company will not accept any funds from Clients or prospective Clients until a risk assessment in terms of the Risk Matrix has been conducted and the Client's risk level has been established.
4.4.2. The Company determines the overall ML/TF/PF risk rating of a Client, in accordance with the Risk Matrix.
4.4.3. The outcome of the risk assessment also determines the level of the CDD to be conducted by the Company, including what CDD information and documentation are required for identity verification. Where the risk assessment determines the ML/TF/PF risk rating to be:
4.4.3.1. Low - standard CDD must be conducted.
4.4.3.2. Medium - standard CDD must be conducted.
4.4.3.3. High - enhanced CDD must be conducted.
4.4.4. It is recorded that the Company does not conduct simplified CDD in respect of low-risk Clients, but rather conducts standard CDD in respect of both low and medium risk Clients. For high-risk Clients, enhanced CDD must be conducted.
4.5. Risk Assessment Process
When conducting a risk assessment, the following risk assessment process must be followed:
4.5.1 All new Clients of the Company must be screened for risk associated with ML/TF/PF in accordance with the Risk Matrix of the Company. Such screening will be conducted by the Compliance Team.
4.5.2 The Compliance Team will conduct the screening based on information obtained from the Client during the engagement process, such information to be appropriate for an accurate risk rating of the Client to be conducted.
4.5.3. Once a Client has been risk rated according to their level of risk using the Risk Matrix, the Compliance Officer must consider whether a relationship may be engaged with that particular Client, in accordance with the following:
4.5.3.1. If the risk rating is low or medium, the Compliance Officer may approve the engagement, subject to the necessary CDD being conducted in respect of the Client.
4.5.3.2. If the risk rating is high, the Compliance Officer must without delay inform Senior Management of the risk rating and obtain Senior Management approval for the engagement. Any high-risk Client approved by Senior Management will be subject to enhanced CDD being conducted in respect of the Client.
4.5.4. In the event that the Company engages with a Client, the Compliance Team will proceed to conduct the necessary CDD in respect of the Client.
4.5.5. Ongoing account monitoring must be conducted in relation to relationship to ensure that the risk level of the Client is monitored for the duration of such relationship in accordance with Client monitoring processes.
4.6. High Risk Clients
4.6.1. The Company will not establish a relationship with a Client in instances where:
4.6.1.1. the Client is a listed terrorist or linked directly to listed terrorists or terrorist financing organisations;
4.6.1.2. the Client has money laundering convictions or substantive money laundering charges pending against them or is linked directly to persons convicted of or facing such charges.
4.6.1.3. the Client has corruption convictions or substantive corruption charges pending against them or is linked directly to persons convicted of or facing such charges: or
4.6.1.4. Senior Management has determined the risk in relation to the Client to be unacceptable.
5. Client Due Diligence Controls
5.1. General
5.1.1. The following persons are deemed to be prospective Clients or Clients of the Company:
5.1.1.1. Natural persons, including:
5.1.1.1.1. Individuals
5.1.1.1.2. The trustees, beneficiaries and/or trust founder of trusts.
5.1.1.1.3. Individuals who are partners in a partnership.
5.1.1.1.4. Shareholders of companies and members of close corporations
5.1.1.2. Non-natural persons, such as:
5.1.1.2.1. Public, private, and state-owned compare
5.1.1.2.2. Close corporations
5.1.1.2.3. Legal persons or association
5.1.1.2.4. Public institutions.
5.1.1.2.5. Organs of State.
5.1.1.2.6. Non-profit organisations.
5.1.1.2.7. Any other form of entity that is not a natural person.
5.1.2. Clients and prospective Clients may engage the Company to perform the services contemplated in paragraph 4.1 from time to time.
5.2. Anonymous Clients
The Company shall not establish a relationship with an anonymous client or a client who has an obvious false or fictitious name.
5.3. Relationship with a Client
5.3.1. When establishing a relationship, the following information must be obtained from the Client, together with the relevant CDD:
5.3.1.1. The nature of the relationship.
5.3.1.2. The intended purpose of the relationship.
5.3.1.3. The Source of Funds which the prospective client expects to use in concluding transactions.
5.3.2. The extent of the CDD to be collected by the Company in respect of every Client shall be informed by its Risk-based Approach.
5.3.3. Standard CDD may be conducted for al low, medium, and high-risk relationship. Enhanced CD must additionally be conducted for all high-risk relationship. The Company must increase the intensity of its verification of the veracity of information obtained from the Client and ongoing account monitoring in the case of high-risk Clients.
5.4. CDD Process
5.4.1 The following processes must be followed when conducting CDD on the different types of prospective Clients and existing Clients:
5.4.1.1. At the engagement of a prospective Client, the Company must obtain sufficient information from the prospective Client to enable the Compliance Team to conduct a risk assessment in respect of the Client.
5.4.1.2. Depending on the risk rating of the Client, and subject to Senior Management approval for high-risk Clients, the Client may be accepted, and the relevant employee or department must be informed that they may continue with the transaction.
5.4.1.3. Following acceptance of the Client, the Client will be requested by the Compliance Team to submit the relevant CDD information and documents. Such requests can be submitted via emails, telephonically or via representatives of the Company.
5.4.1.4. The Compliance Team will review the veracity of information and documents/electronic records to ensure that they are in order and complete and confirm the identity of the Client, and where necessary request further information or documentation from the Client or engage the assistance of the relevant employee or department to assist with obtaining such information.
5.4.1.5. Where third party sources of information or existing CDD information of a Client or parties related to a Client are available to the Company, the Compliance Team may also make use of such sources to conduct and complete CDD in respect of a Client.
5.4.1.6. Ongoing CDD must be conducted in respect of relationship.
5.4.2. When establishing a relationship for Clients that are non-natural persons such as companies or trusts, the nature of the Client's business and the Beneficial Owners of the Client must be established.
5.5. Ongoing CDD
5.5.1. The intervals at which Ongoing CDD is conducted in respect of relationships is dependent on the risk rating of the client.
5.5.2. In addition, ongoing CDD must be conducted when the following scenarios occur:
5.5.2.1. if during account monitoring a change in the Client transaction pattern is detected which is suspicious.
5.5.2.2. The Client undertakes a complex or unusually large transaction or engages in unusual patterns of transactions which have no apparent business or lawful purpose or are inconsistent with the Company's knowledge of the Client or the Client's business or risk profile.
5.5.3. In respect of high-risk Clients as part of enhanced CDD, information or documentation in support of the source of funds of the Client should as far as reasonably possibly be obtained from the Client and be used to confirm the legitimacy of the source of funds.
5.5.4. Where there is doubt as to the accuracy of previously obtained information, the Company must repeat the process of collecting CDD (where relevant), as often as needed to confirm the information previously obtained.
5.6. Inability to Conduct CDD
5.6.1. The Company must ensure in any request for CDD information or documentation that the Client is informed of the consequences (as set out below) of a refusal to provide the required CDD to the Company.
5.6.2. Where a Client refuses to provide the necessary CDD information or documentation, the Company –
5.6.2.1. may not establish a relationship with the Client;
5.6.2.2. may not conclude a transaction in the course of a relationship:
5.6.2.3. must terminate an existing relationship with the Client.
6. Politically Exposed and Prominent Influential Persons
6.1. Prospective Clients and their Beneficial Owners that qualify as PEP's and PIP's, as well as their closely associated persons (which includes their family members and known close associates), are regarded as high-risk clients and should be carefully assessed by the Company prior to engaging in a relationship.
6.2. The Company is required to both when it establishes a relationship (as well as during the existence of the relationship) with a Client, establish whether the Client or Beneficial Owners of such a Client is a PEP or PIP, or an immediate family member or close known associate of a PEP or PIP.
6.3. To establish whether a Client or Beneficial Owner is a PEP or PIP or a closely associated person, the Compliance Team must screen every prospective Client and its Beneficial Owners against the information provided by the client, local databases as well as international sanctions and watchlists. Where necessary, the Compliance Team should further screen results with internet searches as well as other available information sources, media, and public domestic and international government websites.
6.4. The Compliance Team must continuously remain alert to public information relating to Clients and Beneficial Owners and which may result in a change in their status as regards to being a PEP or PIP or closely associated person.
7. Terrorist and Proliferation Financing
7.1. The Security Council of the United Nations from time to time adopts resolutions providing for financial sanctions which entail the identification of persons or entities against whom member states of the United Nations must take the actions specified in the resolutions.
7.2. The Company must be in a position to determine whether they have a sanctioned person or entity as a Client or whether a prospective Client is a sanctioned person or entity in order to determine their exposure to ML/TF/PF-related obligations. Therefore, The Company which are likely to encounter sanctioned persons or entities must screen Clients and prospective Clients against the relevant sanction lists.
7.3. The Company is required to both when it establishes a relationship (as well as during the existence of the relationship) with a Client screen the Client against the UN 1267 sanctions list (as published on the UNSC website).
7.4. In order to screen prospective Clients, the following Client information (as applicable to the Client) must be obtained as part of the Client engagement process or accompanying CDD process, in order to enable effective screening of the Clients against these source lists:
7.4.1. Name;
7.4.2. Surname;
7.4.3. Identity number;
7.4.4. Registration number;
7.4.5. Person acting on behalf of Client; and
7.4.6. Transaction or payment information.
8. Client Account Monitoring
8.1. Assessing the risk rating of any Client with which the Company has a relationship remains a constant obligation and the Company must continuously monitor such Clients and their transaction accounts with the Company to establish whether the Client's risk profile has changed.
8.2. This requires that the Company monitor Client accounts to determine whether transactions with the Company are consistent with the Company's knowledge of the Client and whether any suspicious or unusual conduct or activity may be present or where the transaction is unusually large or has no apparent business or lawful purpose.
9. Reporting
9.1. Reportable Transactions
9.2. Reporting Process
9.2.1. The following process must be followed to identify reportable Cash transactions: the Company will check statements every day to determine whether cash transactions above the threshold have been paid or received and whether any suspicious and/or unusual transactions occurred.
9.2.2. Where reportable transactions are identified, the following process must be applied: the relevant employee must report the transaction to the Compliance Officer without delay. After analysing the report, the Compliance Officer must inform Senior Management and, if required, file the necessary report with the Regulator, within the prescribed timeframes.
9.2.3. It is recorded that:
9.2.3.1. The Company does not accept Cash Transactions and therefore does not have Cash Threshold Reporting requirements.
9.2.3.2. A suspicious report filed with the regulator within stipulated time period defined by the Regulatory Body.
9.2.4. There is an obligation to report a transaction when an employee knows of certain facts, or reasonably ought to have known or suspected that certain facts exist that make a transaction suspicious. Where these scenarios occur, the Company must undertake further assessment to determine whether the transaction/activity is suspicious or unusual or otherwise constitutes another reportable transaction/activity.
9.2.5. The Company is under an obligation to report a transaction an employee knows of certain facts, or reasonably ought to have known or suspected what certain facts exist what make a transaction suspicious and involve an element of terrorist financing or a related activity. Annexure C' contains various Client and transaction profile scenarios which constitute examples of potential suspicious and unusual transactions.
9.2.6. The Compliance Officer must examine complex and unusually large transactions and unusual patterns of transactions which have no apparent business or lawful purpose by, amongst other methods, reviewing applications, statements, credit reports, annual financial statements, etc. (as may be relevant to the particular Client and transaction). as and when such transactions occur, in order to identify possible reportable transactions. Employees of the Company dealing with Client matters must also be vigilant and report any complex and unusually large transactions and unusual patterns of transactions which have no apparent business or lawful purpose to the Compliance Officer without delay.
9.2.7. The Company must keep written findings of decisions taken on whether to report or not to report any circumstances to the Regulator.
10. Record Keeping
10.1. All Client information records will be stored electronically and where applicable hard copies of such information may also be stored in physical files.
10.2. All Client transaction records will be stored electronically on the Company network and where applicable hard copies of such information may also be stored in physical files.
10.3. Client records will be retained by the Company for a minimum period of 5 (five) years calculated from the date on which the transaction is concluded or date of termination of a relationship, or date of a report being filed.
10.4. The Company will maintain a register of all reports made to the Regulator which will include the date on which the report was made, the person making the report and sufficient information and details regarding the transaction.
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