fund governance review 2017 · asset revolution 07 proposed fca changes to the governance of u.k...
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FUNDGOVERNANCEREVIEW2017
D M S G O V E R N A N C E . C O M
01 EXECUTIVE SUMMARY
03 MANAGING REGULATORY RISKS
04 GOVERNING THE DIGITAL ASSET REVOLUTION
07 PROPOSED FCA CHANGES TO THE GOVERNANCE OF U.K AUTHORIZED FUND MANAGERS
08 MIFID
09 CENTRAL BANK OF IRELAND’S REFORMS – THE DMS RESPONSE
10 WHAT’S NEW AT DMS?
14 CAYMAN UPDATE
16 DMS INVESTMENT FUNDS SUMMIT 2018
D M S G O V E R N A N C E . C O M
We are pleased to present our 2017 Fund Governance Review.
Following a tumultuous 2016, there had been concerns over whether
worldwide political issues would continue to have an effect on the
markets in 2017. What is certain is that 2017 was a year of surprises
and political risk taking. General elections across Europe, a new U.S.
President together with drawn-out Brexit negotiations have continued
to cause ripples.
For the governance and compliance world, milestones such as
MIFID II and the FCA changes to the Governance of U.K. Authorized
Fund Managers have had a big impact, as had CP86 and the recent
Cayman Islands AML updates. DMS welcomes and fully supports
the proposed regulatory reform and policy changes which are set
to improve transparency and increase investor protection and both
DMS and its clients are well-placed to move forward following these
changes in legislation.
Undoubtedly one of the year’s top stories is the rise of crypto
currencies. In a year of soaring crypto currency prices and countless
initial coin offerings, it’s perhaps unsurprising that, over the course
of 2017, regulators worldwide stepped in to define how they would
oversee an uncertain environment.
Regulators from many of the world’s leading economies issued
investor alerts and cautionary statements making 2017 perhaps one
of the most significant years to date on the regulatory front.
At DMS, we saw increased growth activity during 2017 and in August
we opened second Asian office in Singapore in response to demand
for our client services in the Asia-Pacific region. We believe the key to
our continued success is our ability to, despite the changing world,
offer our clients a service that is high-quality, reliable and consistent.
EXECUTIVE SUMMARY
FUND GOVERNANCE REVIEW 2017EXECUTIVE SUMMARY
ANNE STORIECHIEF EXECUTIVE OFFICER
D M S G O V E R N A N C E . C O M
01
D M S G O V E R N A N C E . C O M
With the imposition of the CIMA Administrative Fines
Regime (“CAFR”) in 2018, regulated funds should become
more proactive when managing their regulatory risks.
While the implementation of the CAFR simply brings CIMA
in line with other international regulators, this unfamiliar
environment also brings new regulatory risks that should
now become a top fund governance priority among fund
operators.
CIMA has promulgated an extensive framework of financial
regulatory laws, regulations, statements of guidance,
industry alerts, for example, so there are numerous areas
of potential breaches where penalties can be imposed on
regulated entities. Fines range from a minimum of $6,250
for minor offenses to $1.25 million for serious offenses,
meaning the risk-reward exposure gap is large. The
imposition of a fine may have a significant impact on the
reputation, or even in the more serious cases, the financial
position of a fund.
Like other regulators operating under IOSCO standards,
CIMA conducts regular examinations of its regulated
entities including random and targeted sweeps on relevant
issues. These can be expected to increase in 2018 and
beyond. CIMA generally does not engage in aggressive
enforcement theories, but it does expect sound application
of its existing requirements.
Fund operators should ensure that an effective CIMA
compliance program that operates across all relevant
Cayman Islands legislation is implemented. Deadlines
and responsibilities under the Cayman Islands financial
regulatory laws need to be carefully monitored and met.
Some dates are fixed, others are floating and others may be
futuristic, or triggered by the activity of the regulated fund.
However, DMS recommends that fund operators maintain
a compliance calendar of critical responsibilities and
dates for their regulated funds and document compliance
against those responsibilities. Compliance should be well
documented not vague or generic or conflict with the
compliance manual.
DMS recommends the CIMA compliance calendar be
reviewed at each board meeting, vetted and approved
by the directors and senior management to address
any vulnerability. A comprehensive review should be
conducted at least annually by a qualified compliance
expert to give prudent advice and remediate corrective
action where necessary. This is one way that fund operators
can create long-term value and market differentiation.
While the fast-changing fund governance environment
demands ever-increasing oversight and presents new
challenges for funds with scarce resources or no resources
in the Cayman Islands, there are several smart ways to
reduce the regulatory burden and mitigate regulatory risk
using technology and outsourcing.
MANAGING REGULATORY RISKS
FUND GOVERNANCE REVIEW 2017MANAGING REGULATORY RISKS
03
D M S G O V E R N A N C E . C O M
One of the big stories in 2017 was undoubtedly Crypto
Currencies. Distributed ledger (DL) technology is the
foundation on which crypto-currencies are based and
Bitcoin, the most well-known of these, is an attempt to
solve the problem of storing and transferring value in a
digital, decentralized system.
There are over 1,300 crypto currencies in the market today
with a total market capitalization of $500bn+. With more
and more appearing each day, crypto currencies appear to
be the modern day gold rush. The amount of attention they
generate on a daily basis has created a good old-fashioned
“fear of missing out” amongst investors and consumers
alike. With this level of growth, crypto currencies have
found a place as an asset class in investment portfolios as
an alternative to the traditional alternative assets such as
real estate and commodities.
This has sparked the rise of crypto currency hedge funds.
Autonomous NEXT, a FinTech analytics firm, has counted
75 crypto hedge funds that have raised about $800 million
to date and who aim to raise $1.2 billion more in the near
future. The crypto funds strategies range from investing
in initial coin offerings, widely known as ICOs, which raise
money by selling investors digital tokens in exchange for
crypto currencies, to buying and holding traditional crypto
currencies such as Bitcoin, Ethereum and Litecoin.
Much has been made of Bitcoin’s volatility. Certainly,
compared to more established asset classes like equity
long short, the daily price moves can seem volatile. The
relative lack of breadth and depth in the Bitcoin market,
regulatory uncertainty and the presence of significant
players with the ability to shift market sentiment no doubt
also contribute to this sense of risk.
However, an observation of the daily historical volatility of
Bitcoin shows that, in general, its daily vol ranges between
4 and 7 and is not particularly shocking when compared to
many options markets. It is the vol of vol that is striking – with
sudden gap ups to 10, 20 or 40 that quickly recede. Until
recently, most of these shocks have been to the upside,
and as actual or short positions have been impossible until
recently, have not hurt anyone aside from a regretful seller.
As margin and shorting come into play, this vol of vol will
have greater potential impact, but should, if the market
develops gradually, recede in magnitude and frequency.
Cryptocurrencies seem to straddle the boundary between
commodity, security and currency. Earlier this year the
U.S. CFTC approved the first Bitcoin options exchange.
Subsequent to this announcement, the SEC issued an
investigative report which concluded that tokens offered
and sold by a “virtual” organization known as “The DAO”
were securities and therefore subject to the federal
securities laws.
GOVERNING THE MODERN-DAY GOLD RUSH
04 FUND GOVERNANCE REVIEW 2017GOVERNING THE MODERN-DAY GOLD RUSH
FUND GOVERNANCE REVIEW 2017GOVERNING THE MODERN-DAY GOLD RUSH
05
D M S G O V E R N A N C E . C O M
Many countries like Bangladesh, Bolivia, Thailand, and Vietnam (among many others) have tried to ban crypto currencies like Bitcoin, others such as China and South Korea have entirely banned ICOs. There are however some countries for example Australia, Russia, Japan, and Venezuela that have made Bitcoin an official legal tender and are currently regulating it.
Perhaps not unexpectedly, the surge in crypto currencies has led to an abundance of scams, prompting global regulators to warn investors of fraudsters. The U.S. SEC, U.K. FCA, Singapore MAS have all released statements warning investors of inherent risks involved with crypto currencies. As part of its effort to fight cybercrime and protect retail investors from cyber threats, the U.S. SEC announced the creation of a new cyber task force. Amongst other things, the unit will target ICOs and other violations involving distributed ledger
technology that go against SEC regulations.
Regulators globally have been working on determining
appropriate crypto currency regulations for several years,
however, it has only been the recent surge in crypto
currencies that have led them to dedicate a large amount
of resources to find the appropriate resolution.
One thing that the digital asset market currently lacks is a
vibrant community of service providers willing to engage
with it. While a few have taken on this business, many are
adopting a wait and see approach. DMS created a Digital
Asset Working Group to attempt to formulate SEC industry
best practices around DL strategies, including crypto.
The group includes representation from all parts of the
ecosystem including banking, auditor, administrator, legal,
tax, compliance and governance.
With all the unknowns, it seems firms can either wait for
regulatory clarity or make a good faith effort. DMS suggests
adopting the following stance:
• Select the most suitable jurisdiction to incorporate.
• Carry out in-depth due diligence on the trading
exchanges is pivotal as is ensuring all necessary
documentation is in place.
• Start with a simple approach of first ensuring
acceptance of fiat currency for subscriptions and
redemptions.
• Avoid crypto in-kind capital transactions.
• Clearly document all research and trading processes.
• Identify the most suitable key service providers.
• Clearly understand taxation responsibilities and
ensure correct documentation of them. Provide
sufficient oversight and governance.
DMS has led the creation of a Digital Assets Working
Group in an attempt to act as a clearinghouse for best
practices among service providers to these sorts of funds.
In addition, we are actively coordinating with U.S. and
global regulators to communicate these efforts and report
feedback on our efforts.
D M S G O V E R N A N C E . C O M
D M S G O V E R N A N C E . C O M
During the summer months of 2017, the Financial
Conduct Authority (FCA) published findings of its asset
management market study, leading to an announcement
of a series of remedies for the concerns it identified. (For
the full report, click here).
Of particular note for U.K. Authorised Fund Managers
(AFMs) were the findings of the final report which include
the requirement for AFMs to appoint a minimum of two
independent directors to their boards and for at least 25%
of the board to be independent, non-executive directors.
The FCA said they had, “listened carefully to the feedback
we received in response to our report last November” and
had, “put together a comprehensive package of reforms
that will make competition work better and help both
retail and institutional investors to make their money work
well for them”. The FCA also revealed that they believe
governing bodies should have a more defined role to
increase accountability and to work for a better outcome
on behalf of the investor.
DMS is able to provide AFMs with robust, institutional-
quality governance solutions, delivered by industry experts
and powered by the latest developments in FinTech and
RegTech. DMS delivers experienced and skilled fund
directors and governance solutions required to fulfil any
independent non-executive director role. We also provide
the necessary institutional support and reporting needed
to assist with discharging all legal and regulatory duties
and obligations.
We therefore welcome and fully support these proposed
regulatory reform and policy which will improve
transparency and increase investor protection. We have
always led the charge in European fund governance with our
AIFMs, UCITS Management Company and MiFID solutions
which recognise the importance of clear guidelines to
enable compliance with regulatory requirements.
FCA CHANGES TO THE GOVERNANCE OF U.K. AUTHORIZED FUND MANAGERS
FUND GOVERNANCE REVIEW 2017FCA CHANGES TO THE GOVERNANCE OF U.K AUTHORIZED FUND MANAGERS
07
MIFID II
D M S G O V E R N A N C E . C O M
08 FUND GOVERNANCE REVIEW 2017MIFID II
D M S G O V E R N A N C E . C O M
FUND GOVERNANCE REVIEW 2017CENTRAL BANK OF IRELAND’S REFORMS – THE DMS RESPONSE
When the Central Bank of Ireland’s CP86 comes into
full effect in July of this year, it will refine some key
management functions and will increase focus on effective
supervision and enhanced governance standards for
UCITS management companies, alternative investment
fund managers, self-managed UCITS and internally
managed alternative investment funds.
While the strengthening of governance within the Irish
funds industry is to be welcomed, the new requirements
will increase the regulatory burden in particular on self-
managed UCITS and internally managed alternative
investment funds.
At the heart of these reforms is the change in the description
of the role of the designated person (as it relates to the
discharge of each key management function). While this
has been a compulsory concept for UCITS since 2011 and
for AIFMs since 2013, it is the new enhanced focus on
designated persons in CP86 that gives the industry a clear
indication of the Central Bank’s expectations.
The reforms outline that the designated person role
is distinct from the role of a director, requiring day-to-day
involvement in operations and there is also a new focus on
the suitability of candidates who might fulfill the role.
Boards now face the challenge of considering each key
management function and of being sure they can reconcile
the answers to the following questions:
1. Who can assume the designated person role?
2. Who should assume the designated person role?
3. Who will the Central Bank expect to assume the
designated person role?
DMS is uniquely placed to respond to these challenges.
Our Central Bank authorized AIFM and UCITS Management
Company (DMS Investment Management Services) has
introduced a range of solutions to assist clients in complying
with the CP86 requirements. By utilizing the latest forensic
governance techniques and industry-leading technology,
we are able to provide the experienced and skilled
individuals required to fulfil any designated person role.
DMS Investment Management Services also provides
the necessary institutional support structure needed to
assist with discharging all legal and regulatory duties and
obligations.
Our team of experienced and industry-recognized
professionals has expertise in fund governance, risk
management, portfolio management, distribution, finance
and operations, regulatory compliance and reporting
requirements.
The DMS global infrastructure and its market insight means
we are best placed to support our clients’ business with
the Central Bank’s changes and guide them through the
evolving and ever increasing regulatory requirements.
CENTRAL BANK OF IRELAND’S REFORMS – THE DMS RESPONSE
09
MiFID II has been amongst the broadest of financial industry
legislations to come into play in the recent past. The scale
of these changes provides significant challenges to asset
managers and to their I.T. and data management systems,
complicating an already heavy compliance burden. The
challenge is greatest for those firms that are captured by
MiFID II in its entirety.
The European legal framework for investment managers
draws a distinction between investment managers that
provide “collective portfolio management” and would
typically be authorized under AIFMD or the UCITS Directive
in respect of that service, and those investment managers
that provide the service of individual portfolio management
and are typically authorized under MiFID as “investment
firms”. This latter category also covers investment managers
established in the EU that provide sub advisory services to
an AIFM (including AIFMs established outside the EU) or
a UCITS management company (or a self-managed UCITS
funds) and do not act as AIFMs or UCITS management
companies themselves.
DMS Market Access is an authorized MiFID investment
firm that sits alongside and works with DMS Investment
Management Services, (the AIFM and UCITS Man Co). This
allows DMS to provide flexibility and expertise when it
comes to providing MiFID solutions to our clients.
The scope of the legislation means that, now more than
ever, investment managers must think extremely carefully
about the solutions that are available to them and they
must choose a compatible vendor that understands the
complexities of their operations.
DMS Market Access can provide a range of services to
support our clients to cope with MiFID II. These include;
transaction, position and trade reporting, execution,
middle office, distribution and product oversight.
In Addition, through our vast experience of MiFID
compliance, our depth of knowledge of global regulatory
frameworks, inherent fund governance DNA, and unrivalled
client relationships, DMS is well-placed to provide a
licensed suite of solutions that span full MiFID hosting.
The impact on the funds industry will be wide-reaching,
affecting aspects of marketing and distribution, trading and
research, and day-to-day operations. Our comprehensive
MiFID II solution gives managers the ability to continue to
seamlessly service their existing clients while accessing
capital in Europe.
WHAT’S NEW AT DMS?
D M S G O V E R N A N C E . C O M
10 FUND GOVERNANCE REVIEW 2017WHAT’S NEW AT DMS?
D M S G O V E R N A N C E . C O M
FUND GOVERNANCE REVIEW 2017WHAT’S NEW AT DMS?
11
In August last year, DMS opened its first office in Singapore.
It was just over six year ago that DMS opened its first Asia-
Pacific Region office in Hong Kong and since them our
client base in the region has enjoyed significant growth
not only in Hong Kong but throughout the wider Asia-
Pacific region. As a result, we took the decision to open an
office in Singapore to provide our clients with a team of
local experts. We feel this new location goes a long way to
strengthen our presence and our capacity in the region.
We are able to offer professional, independent directors in
the Asia time zone (SGT) and with fluency in Mandarin and
Cantonese language skills that are key to the region.
The office serves not only hedge fund clients but also
those involved in private equity and venture capital. DMS’
clients include some of the largest asset managers in Asia
as well as start-up and emerging funds. The office will also
service clients in other service offerings including banking
+ custody, AIFMD/UCITS and International Tax Compliance
(FATCA/CRS) all of which have seen continued growth.
For DMS, the Singapore office represents another exciting
milestone in our commitment to the asset-management
industry in Asia and we continue to see an increased
demand for our professional directorship services along
with our other Risk & Compliance services in the region.
DMS is now better placed geographically to continue to
achieve the best results for its clients in this region.
LAUNCH OF THE SINGAPORE OFFICE
DMS LAUNCHES ITS NEW U.S. REGULATORY COMPLIANCE SERVICES
D M S G O V E R N A N C E . C O M
12 FUND GOVERNANCE REVIEW 2017WHAT’S NEW AT DMS?
At the end of last year DMS announced the launch of its
U.S. Regulatory Compliance services, designed to support
U.S. based investment advisers in improving the quality
and increasing the ease of compliance with their regulatory
responsibilities.
These new services offer expert compliance staff and
state-of-the-art technology to the investment advisers of
hedge and private equity funds, registered mutual funds,
exchange-traded funds, and other alternative investment
products. We provide clients with practical, real-world
perspective and proven solutions.
Leading the team, based in New York, is Wade Boylan,
“Our mission is to partner with U.S. investment advisers to
provide (1) strategic advice allowing clients to anticipate
and adapt to regulatory compliance developments, (2)
robust compliance services to support the day-to-day
compliance obligations of investment advisers, and (3)
advice on best practices to maintain internal compliance
excellence.”
William Woolverton, Managing Director of DMS comments
that, “As the scale of our governance, risk, and compliance
platform has increased dramatically over the years, DMS
has continued to innovate its product in order to offer its
clients easy access to high-quality, consolidated services at
fair and reasonable fees.”
DMS has a successful, long-term track record and expertise
in governance, risk, and compliance within the investment
fund industry and our unique position within the market
means it was a natural step for U.S. to take to advise not
only on regulatory compliance issues, but also to act as a
practitioner with regulatory interfaces in multiple global
jurisdictions.
In February 2017, DMS announced the immediate
relocation of a team of executives to augment its expansion
to a planned 20 employees by the end of 2018.
Managing Director, Darren Gorman is responsible for the
oversight of recruitment of experienced, local professionals
to complement DMS’s unique process and relationship
driven approach. This expansion is necessitated by DMS
being the Third-Party Management Company of choice for
leading institutional Investment Managers in Europe and
the Fund Governance name that U.S. investment managers
know, trust and look to when establishing their European
product.
Darren brings with him over 20 years of compliance and
management experience in regulated financial services
firms in Luxembourg, London and Dublin.
Relocating with Darren are Kim Lattimore who will oversee
compliance, Miriam Wall who will drive client relationship
management and Paddy Foley who will ensure that our
substantive risk oversight and monitoring is performed on
site in Luxembourg.
DMS LUXEMBOURG EXPANSION
D M S G O V E R N A N C E . C O M
FUND GOVERNANCE REVIEW 2017WHAT’S NEW AT DMS?
13
CAYMAN ISLANDS REGULATORY UPDATE
D M S G O V E R N A N C E . C O M
14 FUND GOVERNANCE REVIEW 2017CAYMAN ISLANDS REGULATORY UPDATE
D M S G O V E R N A N C E . C O M
2018 will see significant updates to Cayman Islands AML
Regulations which are certain to have a significant impact
on the funds industry. We are working with our clients to
ensure they are compliance ready following these new
regulations.
On 13 December 2017 the Cayman Islands Monetary
Authority (“CIMA”) issued their updated Guidance Notes
under the new AML Regulations which came into effect on
2 October 2017. These Guidance Notes clarified that all
regulated funds are required to appoint individuals who are
suitably qualified and experienced as Compliance Officer
(“CO”), Money Laundering Reporting Officer (“MLRO”) and
as Deputy MLRO (the first two appointments could be held
by the same person). The requirements for these roles is
extensive with knowledge, experience and independence
at the forefront. (Link to guidance notes http://www.cima.
ky/guidance-notes)
Robust compliance is essential for mitigating any risks and
other related threats to the integrity of the international
financial system. Noncompliant AML/CFT entities could be
subject to severe sanctions that are generally universally
adopted. Under the updated Anti-Money Laundering
Regulations any person who contravenes the Regulations
commits an offence and is liable for a fine of approximately
on conviction on indictment, to a fine and to imprisonment
for two years.
In addition, as of 16 March 2018, CIMA will have the
power to impose administrative fines for breaches of AML
requirements up to approximately U.S.$1.2M.
Currently the administrator is typically appointed to
provide Fund Accounting, AML/KYC on investors and
Transfer Agency services and through this appointment
the Board of the Fund delegates the requirement to have
an AML framework to the Administrator (subject to Board
oversight). We understand that individuals have not been
formally appointed as CO, MLRO and DMLRO for the
Funds in most cases, although individual employees of the
administrator could formally accept these appointments,
if they meet the relevant criteria, including independence.
Investment managers must first, determine with their fund
administrator if these roles have been formally appointed.
If not, DMS Compliance has a team of MLRO, DMLRO and
CO specialists available for appointment that meet the
required criteria.
FUND GOVERNANCE REVIEW 2017CAYMAN ISLANDS REGULATORY UPDATE
15
2018Investment
FundsSummit+-
D M S G O V E R N A N C E . C O M
16 FUND GOVERNANCE REVIEW 2017DMS 2018 INVESTMENT FUNDS SUMMIT –NEW YORK
NEWYORK
In January this year we held the second annual DMS Investment Funds Summit at the Kimpton Eventi in New York. Building on the success of last year’s event we were delighted to welcome over 500 attendees this year from both our global client base and key sectors of the industry.
FUND GOVERNANCE REVIEW 2017DMS 2018 INVESTMENT FUNDS SUMMIT –NEW YORK
17
D M S G O V E R N A N C E . C O M
As well as high-profile speakers from across the industry we also featured a lively “investors vs managers”
debate which covered two topics:
For certain strategies, Alpha is effectively and permanently dead.
2 and 20 is dead, should be dead, and will never return.
We welcomed to the event this year a total of nine speakers on a wide range of topics:
William K. M. Goldsmith, Nantucket Capital Management, LLC
Brendan Kalb, Managing Director & General Counsel, ACQ Capital Management, LLC
David Shrier, Managing Director, MIT Connection Science CEO & Distilled Analytics
Michael Oliver Weinberg, CIO, MOV37 and Protégé Partners
Andrew Weymann, Vice President, Investcorp
Abbas F. (“Eddy”) Zuaiter, Managing Member, Zuaiter Capital Holdings, LLC
Greg Deeds, Senior VP, EACM Advisors
Marc Levine, Chairman, Illinois State Board of Investment
John Brennan, Co-Head of ODD, PAAMCO
We were delighted to welcome David Shrier, MD of MIT Connection Science as our keynote speaker who addressed “The Short Term Future” on how Artificial Intelligence can be used positively and for profit.
18 FUND GOVERNANCE REVIEW 2017DMS 2018 INVESTMENT FUNDS SUMMIT –NEW YORK
FUND GOVERNANCE REVIEW 2017DMS 2018 INVESTMENT FUNDS SUMMIT –NEW YORK
19
D M S G O V E R N A N C E . C O MD M S G O V E R N A N C E . C O M
KEY GLOBAL CONTACTS
20 FUND GOVERNANCE REVIEW 2017KEY GLOBAL CONTACTS
FUND GOVERNANCE REVIEW 2017KEY GLOBAL CONTACTS
21
D M S G O V E R N A N C E . C O M
ANNE STORIECHIEF EXECUTIVE OFFICERCayman [email protected]+1.345.749.2584
DEREK DELANEY
[email protected]+353.1.619.2300
CAOIMHGHIN O’DONNELLMANAGING DIRECTOR [email protected]+353.1.619.2375
COLM O’DRISCOLLMANAGING DIRECTORCayman [email protected]+1.345.749.2795
MURRAY MCGREGOR
Cayman [email protected]+1.345.749.2538
HEAD OF STRUCTURED FINANCE
JELANA ECKHARDTDIRECTORCayman [email protected]+1.345.749.2559
ALAINA DANLEYMANAGING DIRECTORCayman [email protected]+1.345.749.2455
KEVIN A. PHILLIPMANAGING DIRECTORCayman [email protected]+1.345.749.2590
JOHN D’AGOSTINO
New [email protected]+1.212.257.5051
WILLIAM H. WOOLVERTONMANAGING DIRECTORNew [email protected]+1.212.403.2781
WADE BOYLAN
New [email protected]+1.212. 403.2783
EXECUTIVE DIRECTOR - COMPLIANCE REGULATORY SERVICES
DON W. EBANKSMANAGING DIRECTORCayman [email protected]+1.345.749.2562
CHIEF OPERATING OFFICER
HEAD OF INVESTOR ENGAGEMENT
D M S G O V E R N A N C E . C O M