CORPORATE OVERVIEW

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Corporate Infrastructure, Scope of Operations & Philosophy: TRAAG a Maltese holding company, is a privately-owned trader, exclusively for its own account, in investment grade governmental and institutional securities.

 

Further, TRAAG is the parent to: TRAWW, LTD. in the United Kingdom, TRAWW Swiss Branch, TRAWW, SARL in France and TRAWW, LLC in the United States (collectively “TRAAW”). TRAWW acquires mined gold and grandfathered stocks all as defined by the Organization for Economic Co-operation and Development (“OECD”) as well as out of compliance London Bullion Market Association (“LBMA”) bullion (all hereinafter collectively referred to as “Doré”) on a worldwide basis. This structure maximizes operational efficiencies in both securities trading and commodity intermediation aforesaid. TRAWW has a separate web presence that address its Compliance and Corporate Overview.

 

TRAAG trade activity is focused at the development of funding for the deployment of extraordinary technologies to meet real world requirements for: water, power, housing and food on a humanitarian basis. Toward this objective, TRAAG trades in investment grade securities, exclusively utilizing only its own capital. TRAAG does not trade for or on behalf of any third-party entities or individuals in any jurisdiction whatsoever. TRAAG does not accept nor utilize third-party funding whatsoever. TRAAG trades only with and between vetted Qualified Institutional Buyer counterparties. TRAAG maintains bank, institutional brokerage, insurance and reinsurance company, pension fund, hedge fund and finance company relationships across North America, Europe, the Middle East and Asia toward its objective in conformity with its business model. These relationships, informed by unrivaled infrastructure, capacity and experience augment TRAAG’s ability to conduct its professional fully compliant securities operations.

 

TRAAG, and its related entities, operate globally and take pride in our global reputation for integrity and honesty. It is essential that TRAAG employees, counter-parties and all those associated with TRAAG, protect that reputation. As TRAAG will not perform any banking or cash management services for third-parties and will interact in transactions exclusively with Qualified Institutional Buyer counterparties, most of the associated anti-money laundering (“AML”) risks are rendered irrelevant. The foregoing notwithstanding, TRAAG is subject to reputational risk should it not perform to the standards it sets for itself. TRAAG mitigates reputational risk through a rigorous vetting process used in on-boarding Qualified Institutional Buyer counterparties.

 

TRAAG Group maintains rigorous AML, KYC and Securities Compliance policies and procedures which are built around and fully comply with all relevant legislation and industry standards. Money laundering, bribery and corruption are criminal offenses. In addition to the fines, penalties and reputational harm that TRAAG may suffer, such activities can lead to untoward human rights abuses and conflict financing. Employees, counterparties and all those associated with TRAAG involved in money laundering, bribery and or corruption will be terminated. Third parties doing business with TRAAG are expected to comply with all applicable laws and adhere to our policies and contract provisions relating to the prevention of money laundering, bribery and corruption. Moreover, TRAAG works with its employees and counter-parties to ensure they are aware of our policies and procedures.

 

ANTI-MONEY LAUNDERING, BRIBERY AND CORRUPTION POLICY

 

Internal Controls, Procedures & Compliance Management: TRAAG’s integrated anti-money laundering (“AML”) and know your customer (“KYC”) policies, procedures and internal controls are designed to ensure compliance with all applicable statutes, regulations and rules and are reviewed and updated on a regular basis. TRAAG employs on boarding procedures to insure its understanding of the nature, scope, motivation and provenance of those with whom it engages. TRAAG’s Management regularly reviews TRAAG’s policies, procedures and internal controls with professional international audit, taxation and legal counsel to ensure their ongoing efficacy. Further, TRAAG submits to external periodic independent audit of its compliance regimen. TRAAG’s management is vested with responsibility for enforcement and as such a have a working knowledge of statutory regimes including but not limited to: The foreign corrupt Practices Act; The Drug Trafficking Offenses Act 1986, The Criminal Act 1988, the Prevention of Terrorism (Temporary Provisions) Act 1989, The Criminal Justice (International Co-operation) Act 1990, The Criminal Justice Act 1993, and the Money Laundering Regulations 1993 as amended. Accordingly, TRAAG complies with law enforcement requests for information as well as all validly issued orders of courts of competent jurisdiction. Moreover, if TRAAG uncovers suspicious activity during our risk assessment and review, we will elevate that risk assessment in compliance with relevant statutory regimes.

 

Monitoring, Zero-tolerance, Training & Records: TRAAG monitors the provenance of all transactions comprising its trade operations to ensure compliance. TRAAG is committed to a zero-tolerance approach to money laundering, bribery and corruption and will: (i) conduct all our business dealings and relationships in a fair, honest, and ethical manner;  (ii) adhere to all applicable national and international laws and regulations relevant to countering money laundering, bribery and corruption;  (iii) implement and enforce effective systems to counter the risk of money laundering, bribery and corruption; and (iv) prohibit the use of its businesses and services for money laundering, bribery, corruption or other illegal activities conducted through commercial transactions. If a potential or existing counter-party either refuses to provide the information requested, or appears to have intentionally provided misleading information, TRAAG will terminate engagement with that entity or individual. TRAAG maintains AML and KYC documentation regarding each counter-party and transaction. TRAAG maintains ongoing employee training under the leadership of a designated Compliance Officer. TRAAG’s training is based on its policies, procedures and internal controls as well as applicable statues and regulations. TRAAG’s training addresses: (i) identification of red flags; (ii) action upon risk identification, (iii) employees' roles in compliance efforts; (iv) record retention; and (v) the disciplinary consequences of non-compliance.

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