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COMPLIANCE POLICY

CORPORATE OVERVIEW

Corporate Infrastructure, Scope of Operations & Philosophy: eAnalytics, Ltd is  Isle of Man Company with a UAE affiliate (hereinafter “eA”). eAnalytics serves as a thought partner to sovereign counterparties seeking to address real world problems with technological solutions. Toward this objective eAnalytics maintains intellectual collateral through relationships with its associates in North America, Europe, the Middle East, and Asia. These relationships supported by unrivaled infrastructure and unerringly ethical standards allow eAnalytics to provide sovereign counterparties with practical goal-oriented solutions.

 

eAnalytics operates globally taking pride in our reputation for integrity and honesty. It is essential that eAnalytics associates, employees, counterparties, and all those associated with eAnalytics, protect that reputation. Money laundering, bribery and corruption are criminal offenses. In addition to the fines, penalties, and reputational harm that eAnalytics may suffer, such activities can lead to untoward human rights abuses and conflict financing. Associates, employees, counterparties, and all those associated with eAnalytics involved in money laundering, bribery and corruption will be terminated. Third parties doing business with eAnalytics are expected to comply with all applicable laws and adhere to our policies and contract provisions relating to the prevention of money laundering, bribery, and corruption. As a prime actor in eAnalytics the deployment of technology, eAnalytics recognizes it is uniquely positioned to detect and prevent commercial activities that contribute to illegal activities. eAnalytics works with its associates, employees and counterparties to ensure they are aware of our policies and procedures.

 

ANTI-MONEY LAUNDERING, BRIBERY AND CORRUPTION POLICY

Internal Controls, Procedures & Compliance Management: eA’s integrated anti-money laundering (“AML”) and know your counterparty (“KYC”) policies, procedures and internal controls are designed to ensure compliance with all applicable statutes, regulations and rules and are reviewed and updated on a regular basis. eA employs on boarding procedures to ensure its understanding of the nature, scope, motivation, and provenance of those with whom it engages. eA’s Management regularly reviews eA’s policies, procedures and internal controls with professional international audit, taxation, and legal counsel to ensure their ongoing efficacy. Further, eA submits to external periodic review of its compliance regimen. eA’s management is vested with responsibility for enforcement and, as such, possesses a working knowledge and familiarity with related statutory regimes including but not limited to: The foreign corrupt Practices Act; The Drug Trafficking Offenses Act 1986, The Criminal Act 1988, the Prevention of Terrorism (Temporary Provisions) Act 1989, The Criminal Justice (International Co-operation) Act 1990, The Criminal Justice Act 1993, and the Money Laundering Regulations 1993 as amended. Accordingly, eA complies with law enforcement requests for information as well as all validly issued orders of courts of competent jurisdiction. Moreover, if eA uncovers suspicious activity during our risk assessment and review, we will elevate that risk assessment in compliance with relevant statutory regimes.

 

Monitoring, Zero-tolerance, Training & Records: eA monitors all transactions under its purview. eA is committed to a zero-tolerance approach to money laundering, bribery and corruption and will: (i) conduct all our business dealings and relationships in a fair, honest, and ethical manner;  (ii) adhere to all applicable national and international laws and regulations relevant to countering money laundering, bribery and corruption;  (iii) implement and enforce effective systems to counter the risk of money laundering, bribery and corruption; and (iv) prohibit the use of its businesses and services for money laundering, bribery, corruption or other illegal activities conducted through commercial transactions. If a potential or existing Counterparty either refuses to provide the information requested, or appears to have intentionally provided misleading information, eA will terminate engagement with that entity or individual. eA maintains AML and KYC documentation regarding each Counterparty and transaction. eA maintains ongoing employee training under the leadership of a designated Compliance Officer. eA’s training is based on its policies, procedures, and internal controls as well as applicable statues and regulations. eA’s training addresses: (i) identification of red flags; (ii) action upon risk identification, (iii) employees' roles in compliance efforts; (iv) record retention; and (v) disciplinary consequences of non-compliance.

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