Newsletter

Compliance

In order to comply with applicable legal, regulatory and anti-money laundering/counter terrorist financing frameworks in the jurisdictions in which we operate, and for the protection of our clients and our reputation, we conduct a high level of due diligence on all clients and on all business activities undertaken with our offices.

Reporting directly to the Board, Bart Buitendijk (a member of ATC's Executive Committee),together with histeam of Compliance Officers in ATCs worldwide offices,is responsible for our compliance function. Where possible, our Compliance Officers are members of their local compliance associations, which provide them with access to best practices and networks of like-minded and focused professionals and regulators. Some of our Compliance Officers are members of international compliance associations as well.

ATC maintains a practical approach to compliance. We collect all information and documents necessary to fulfill our regulatory responsibilities in the relevant jurisdiction(s), while at the same time ensuring we understand our clients businesses. Our compliance team is involved in inter-office referrals so that any variances in requirements are identified and addressed early on to minimise repetition in the provision of information from our clients. Our objective is to sensibly apply requirements and communicate these to our clients at the outset to avoid cost overruns or increased fees. We do not accept clients who fail to provide us with sufficient or satisfactory due diligence.

We require potential clients to obtain appropriate professional (legal / tax) advice before setting up any structure with us. In certain cases, we will require confirmation that appropriate tax advice has been given.

Other forms of protection for our clients include regular scanning of our database against negative lists and the use
further detailed investigations
where necessary.This protects ATCs reputation and that of our clients from the potential risk of dealing with prospective clients who may have been involved in unethical or illegal dealings in the past or present.The product we use for scanning the database is the same one used by major global financial institutions, as well as regulators and financial investigative authorities, in the jurisdictions in which we operate.

Furthermore, ATC welcomes and supports anti-money laundering (AML), counter-terrorism and tax evasion initiatives and is committed to ensuring that no vehicle or structure in ATC is used to facilitate money laundering, terrorism /terrorist financing or tax evasion. To do this, any new business and changes in existing business brought to ATC will be scrutinised, and the identity of the client and other relevant details will be verified.

Each ATC office maintains a business continuity plan and a disaster recovery plan which are tested regularly.Our clients should be aware that in order to achieve these plans, confidential data is stored securely offsite. Our service provider - who has no access to our data - warehouses our information using i365s Evault technology for secure and effective recovery in the event of a disaster in one of our offices.

Should you have any questions about compliance at ATC, please contact Bart.

Bart Buitendijk
Head of Compliance
+31 20 571 1288
bart.buitendijk@atcgroup.com