The framework makes the Board ultimately responsible for risk oversight and reliable internal controls. Those controls protect assets, support efficient operations, produce accurate reporting, strengthen governance and promote compliance with legal and regulatory requirements.
Detailed controls govern account opening, KYC and AML documentation, customer reporting, account closure, and order placement and execution. New accounts require compliance authorization; customer changes must be documented; and client orders must be authorized, recorded and retained.
Financial controls cover bank accounts, reconciliations, payments, receipts, petty cash, profit calculations and expense approval. IT controls address permissions, passwords, backups, system changes, network safeguards, vulnerability monitoring and disaster recovery.
The Board, Audit Committee, Compliance Officer, management, staff and auditors have defined responsibilities. Controls are reviewed periodically and management must respond to weaknesses, while recognizing limitations such as human error, collusion and changing technology.
This summary is for convenience and does not replace the approved document. If there is any difference, the complete PDF governs.