Internet Fraud Enforcement. Senior management shall employ the MIAFOS™ product through its information clearing system, to provide solutions to the types of “internet fraud” committed, which ranges from basic non-delivery of goods and identity theft to complex investment fraud schemes. Elements of it are designed to serve as a centralized clearinghouse for all transactions irrespective of the nature or tools employed, i.e., the internet and it performs analytical functions by identifying new internet crime trends and developing investigative strategies and tools to address them. Where there is concrete evidence of fraud or the activities that clearly and concisely indicate fraud, the system will refer, on a confidential basis, to the appropriate law enforcement agencies within the respective jurisdiction having authority over the parties.

Money Laundering. The expression “money laundering” covers a wide range of activities and processes with the sole aim to obscure the source of illegally and ill-gotten gain that is structured to create the appearance or illusion that funds are derived from a legitimate source(s). Therefore, directors, officers, employees, authorized agents, and authorized representatives are required to consider the sufficiency of domestic legislation to address the risks of money laundering. For that fact the Directors require that officers, employees, agents, and authorized representatives, such as market intermediaries have in place policies and procedures duly designed to identify and thereby minimize the risk of the use of an intermediary, institution or a vehicle that may be in cahoots with money launderers.

International Enforcement. The international nature of HD Faculty™ and the fact that a number of transactions will cross several jurisdictions gives rise to a number of particular issues. Therefore, from time to time, HD Faculty™ will utilize MIAFOS™ to ensure that it, or a relevant party in another jurisdiction, has the necessary information, including statements and documents, that may be relevant to investigation and prosecution of violations of respective laws and regulations relating to transactions, e.g., securities dealings.

The Scope of Co-operation

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Identification of the circumstances under which assistance may be sought;

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Identification of the types of assistance that can be provided;

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Safeguards of the confidentiality of bona fide clients’ information;

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Description of the permitted uses of the information;

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The amount of access that can be obtained under applicable law;

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Confidentiality and use of restrictions under applicable law;

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The form and timing of the assistance or information sharing; and

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The applicability of other arrangements between the jurisdictional authorities for sharing investigative financial and non-financial information.