Compliance

Introduction
Trust offices in the Netherlands are strictly supervised by the Dutch Central Bank and must apply for a license before operating. To receive a license, various procedural and organisational requirements must be met. IMFC received its license on 23 September 2004.

Legislation in the Netherlands
The Act on the Supervision of Trust Offices (Wet toezicht trustkantoren / Wtt) came into force on 1 March 2004 and aims to promote the integrity of the Dutch financial system. Pursuant to the Wtt, every trust office must have a strict know your customer (KYC) policy, i.e. they must identify their clients and obtain information on client assets, purpose of the structure as well as carefully monitor fund flows - as set out in the Wtt Regulation on Sound Operational Management. Trust offices must also comply with the Act on the Prevention of Money Laundering and Terrorist Financing (Wet ter voorkoming van witwassen en financieren van terrorisme / Wwft) and the Sanctions Act 1977 (Sanctiewet 1977).

IMFC Compliance
IMFC has developed an effective client acceptance and due diligence procedure, which helps us maintain a high level of integrity and safeguard our reputation and the reputation of our clients. We are aware that the information we request is private and sensitive: all information is treated in the strictest confidence and supervised by our compliance department.

Integrity
IMFC does not want any involvement in illegal/unethical activities such as: money laundering, tax fraud, insider trading and financing terrorism. IMFC reserves the right to reject a client or terminate a relationship if KYC questions are not answered satisfactorily or if IMFC becomes aware of any information or conduct which IMFC reasonably believes to constitute a compliance or integrity risk. A high level of compliance helps us provide reliable and high-quality service on behalf of all of our stakeholders.