Considerations to Specific Rules

Selected Rules

The QFC RBP Guidance Notes refer to a number of Rules and Schedules that should be reviewed. These have all been considered in the drafting of this document and are covered within, with further information available in supplementary documents.

A short commentary on the considerations taken from each document is provided below, with further substance throughout the document.

Anti-Money Laundering and Combating the Financing of Terrorism Rules 2019 (AML/CFTR)

We viewed the points covered in this section of the Rules as fundamental to this RBP and to the business of the Authorised Firm. Not least because the points covered in this section speak to the very existence of Tintra as a group; namely that as a company focused on radically improving KYC/AML. Making it a more accurate, less biased, faster and fairer process.

The Groups AI-first banking infrastructure is designed not only to meet, but exceed current anti-money laundering (AML) and know your customer (KYC) requirements greatly reducing the risk of false positives, illicit financial flows and the onboarding of bad actors. Tintra’s approach is endorsed by the FATF, G20, and various global regulatory authorities. We have a full paper on our views on FATF.

Our technology stack patents secure our position as a leader in AML and CFTR. We are in discussion with Governments, Central Banks and Regulators across the world to identify needs and gaps.

This section speaks to EDD’s importance in high risk situations. At Tintra, our entire compliance function provides for Enhanced Due Diligence on ALL customers and accounts not just those that would ordinarily be required.

With reference to AML/CFTR Part 4.3, our tech stack therefore far exceeds what is required both in these Rules but also that required by the PRA/FCA and the SEC.

Relevant to particularly Clauses 3&4, as a strategy, the Authorised Firm, nor the Group, deal with PEP’s.

What’s more, the Authorised Firm’s product suite has been built under PRA guidelines, and our KYC/AML processes based around FATF and Basel II.

Considering this alignment with such regulatory bodies, and our business model based upon industry leading technology, we believe that we are not only compliant with, but far exceed these Rules.

Further details regarding how the Authorised Firm deals with these matters are included in this document and through supplementary documents.

Governance and Controlled Functions Rules 2020 (CTRL) -

The points covered in this section as it relates to the Authorised Firm are something that have been developed in large part through the Group’s interaction with the PRA/FCA; for whom all of our processes and procedures are built.

With risk mitigation being our North Star as a business we not only meet but exceed both sector norms and regulatory requirements by some measure. This is made possible through strict Corporate Governance and Risk Management frameworks. This is covered in Sections E & F of this document and in supplementary documents upon request.

The regulated activities of the Authorised Firm will therefore be exercised above minimum requirements and with and in excess of the CTRL.

Further, the Authorised Firm’s commitment to in-country staffing which is covered in this implementation of, and adherence to, such rules.

With reference to CTRL Part 6.4, the Authorised Firm will have further oversight from the Audit Committee of Tintra plc detailed in Section E of this document.

Customer and Investor Protection Rules 2019 (CIPR)

This section, particularly Chapter 4-6 onwards pertains heavily to customers of trading, insurance and investment businesses. The Authorised Firm will not undertake these activities so the below is silent on them.

The earlier sections relating to customer facing activities are well covered and in fact it is worth noting that the Authorised Firm is a customer-led business whose purpose is to address and solve the problems that individuals face in interfacing with their bank or financial service provider in emerging markets. So that forms part of the DNA of the business. In the initial stages the Authorised Firm’s activities will be limited to payments, with no investment customers, therefore, personal contact with customers will be limited. If and when this element of the business changes, the rules of CIPR Part 4.3 will be complied with.

The Authorised Firm will not be advertising its services or products in any manner, as specified in Part 4.2 of CIPR.

Individuals (Assessment, Training and Competency Rules 2014) (INDI)

The intention of the Authorised Firm is that the full staffing requirement, both Controlled Persons/Functions and other team members will be hired locally in Qatar and operate from QFC approved premises. All the Controlled Persons will be recruited and trained according to the same PRA/FCA standard seeks to hire locally the individuals who will perform controlled functions for the firm. In each of these hires, we will assess the competence, fitness and propriety of such individuals, with careful consideration to Chapter 3 of INDI.

Details of such hires are available in Section B of this document.

Further information on the established training and competency programmes, as detailed in INDI Chapter 5 is available in supplementary documentation should it be required.

As detailed above, there will be no customer facing roles and thus, the rules of INDI Chapter 4 are not of relevance currently.

Banking Business Prudential Rules 2014 (BANK)

The BANK document has been thoroughly reviewed prior to the presentation of this document. The Authorised Firm has produced this information for other regulators and the answers in this document benefit from our thinking and experience of producing these document.

In the first instance we understand that specific referral to these Rules would be unnecessary until such time a full banking licence is being pursued. However, a full set of documentation related to this section is available through supplementary documentation should it be required.

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