Compliance & Ethics

Compliance Architecture

Kaelo Global operates under three distinct regulatory regimes, each with specific conduct requirements, reporting obligations, and enforcement mechanisms. Our compliance architecture is designed to satisfy the most stringent applicable standard across all three jurisdictions simultaneously — rather than operating at the minimum threshold of the least demanding regime. This approach creates operational overhead, but it eliminates the regulatory arbitrage risk that arises when multi-jurisdictional firms calibrate compliance to the lowest common denominator.

The compliance function reports directly to the advisory board, not to executive management. This structural independence — consistent with international best practice for regulated financial services — ensures that compliance considerations cannot be subordinated to commercial objectives. The Chief Compliance Officer has authority to delay or block transactions pending compliance review, with escalation to the board if management disputes a compliance determination. This authority has been exercised. We consider it a feature of the system, not a failure.

All compliance policies are reviewed annually against regulatory developments in each jurisdiction. Policy updates are implemented within 90 days of material regulatory change. The compliance programme is subject to annual independent review by external consultants who assess policy adequacy, implementation effectiveness, and control environment integrity.

DFSA Compliance

Kaelo Global operates from Meydan Free Zone, Dubai as a strategic advisory and management consulting firm. We are not regulated by the DFSA and do not conduct DFSA-regulated financial services activities. For activities requiring DFSA or other financial regulatory authorisation, we work through licensed partners who hold the appropriate regulatory permissions. Kaelo maintains professional indemnity insurance, voluntary AML compliance procedures, and the internal controls that institutional advisory practice demands — not because regulation requires it, but because our institutional clients expect it.

MAS Compliance

The Monetary Authority of Singapore (MAS) operates one of the world's most rigorous financial regulatory environments. Kaelo's Singapore operations comply with the Securities and Futures Act, Financial Advisers Act, and applicable MAS Notices and Guidelines. Business conduct requirements include fair dealing outcomes, product suitability, disclosure obligations, and complaint handling procedures. MAS Notice on Prevention of Money Laundering and Countering the Financing of Terrorism (Notice SFA04-N02) governs our AML/CFT programme in Singapore. Technology risk management follows MAS Technology Risk Management Guidelines.

SIBA Compliance

The Seychelles International Business Authority (SIBA), now operating as the Financial Services Authority (FSA), regulates international business companies and securities activities in Seychelles. Kaelo's Seychelles operations comply with the International Business Companies Act, Securities Act, and applicable FSA regulations. AML/CFT compliance follows the Anti-Money Laundering and Countering the Financing of Terrorism Act as amended. Seychelles' FATF mutual evaluation outcomes inform our compliance calibration for this jurisdiction, and we apply enhanced due diligence measures where the regulatory environment warrants additional controls.

AML/CFT Programme

Anti-money laundering and counter-terrorism financing controls are the foundational layer of Kaelo's compliance architecture. Our AML/CFT programme operates on a risk-based approach consistent with FATF Recommendations and the specific requirements of each regulatory jurisdiction. Client onboarding follows a four-stage process: identification and verification (KYC), beneficial ownership determination, source of funds and source of wealth assessment, and risk classification. Each stage is documented with an auditable trail of evidence, decisions, and approvals.

Politically Exposed Persons (PEPs) and their associates are subject to enhanced due diligence (EDD), including senior management approval for onboarding, ongoing monitoring at elevated frequency, and source of wealth documentation that meets evidentiary standards sufficient for regulatory examination. We apply the broadest available PEP definition across all jurisdictions — if a person qualifies as a PEP under any of our three regulatory regimes, they are treated as a PEP firm-wide.

Transaction monitoring employs both rule-based alerts and pattern recognition for complex multi-layered structures. Suspicious activity reports are filed with the relevant Financial Intelligence Unit in the applicable jurisdiction. Our Money Laundering Reporting Officer (MLRO) has direct escalation authority to the advisory board and operates independently of commercial functions. AML/CFT controls are tested annually through independent audit and regulatory examination.

Sanctions Screening

Kaelo screens all clients, counterparties, beneficial owners, and connected parties against comprehensive sanctions lists including: UN Security Council Consolidated List, US OFAC Specially Designated Nationals (SDN) and Sectoral Sanctions Identifications (SSI) lists, EU Consolidated List, UK HM Treasury Financial Sanctions List, and jurisdiction-specific sanctions lists maintained by UAE, Singapore, and Seychelles authorities. Screening is conducted at onboarding, at every material transaction, and through continuous batch screening against updated lists.

Our sanctions compliance programme accounts for the complexity of operating across jurisdictions with non-identical sanctions regimes. Where sanctions designations differ between jurisdictions — for example, where the US applies secondary sanctions that are not mirrored by the EU or vice versa — we apply the most restrictive interpretation. This is a conservative approach that occasionally constrains commercial activity, but it eliminates the sanctions exposure that arises from differential compliance strategies. Sanctions screening is automated through a licensed compliance technology platform, with manual review of all alerts by trained compliance officers before disposition.

Conflicts of Interest

Kaelo operates both advisory and principal investment activities, which creates inherent conflicts of interest that must be managed through structural controls rather than discretionary judgement. Our conflicts management framework operates on three principles: identification, disclosure, and where necessary, avoidance. Information barriers — enforced through access controls, segregated communication systems, and compliance-monitored crossing procedures — separate advisory and principal activities. Personnel assigned to advisory mandates cannot access deal flow information from principal investment activities, and vice versa, without compliance approval and client notification.

Personal account dealing is restricted for all personnel. Pre-clearance is required for any personal investment in sectors or geographies where Kaelo maintains active advisory mandates. Gifts and entertainment are subject to monetary thresholds, pre-approval requirements, and centralised recording. Outside business interests require board-level approval. Our conflicts register is maintained by the compliance function and reviewed quarterly by the advisory board. Where a conflict cannot be adequately managed through information barriers and disclosure, the firm will decline the engagement. This has occurred in practice, and we consider the willingness to decline revenue a more reliable indicator of conflicts management than the existence of a policy document.

Code of Conduct

The Kaelo Code of Conduct governs the professional and ethical standards expected of all personnel, including permanent employees, contractors, consultants, and any third party acting on behalf of the firm. The code is not aspirational — it defines specific prohibited actions, reporting obligations, and the consequences of non-compliance. All personnel acknowledge the code in writing upon joining and reaffirm annually. The code covers: anti-bribery and corruption, confidentiality and data protection, personal account dealing, market conduct, fair dealing with clients, conflicts of interest, use of material non-public information, and interaction with regulators.

Violations of the code are investigated through a formal disciplinary process overseen by the compliance function with advisory board notification. Sanctions range from formal warning to summary termination depending on the severity of the breach and whether it involved deliberate misconduct or negligent failure to follow established procedures. All investigations are documented and retained in accordance with regulatory record-keeping requirements. The code is supplemented by jurisdiction-specific guidance notes that address local regulatory nuances and cultural contexts.

Whistleblower Protection

Kaelo maintains a confidential whistleblower programme that enables any person — including employees, contractors, clients, and external parties — to report suspected misconduct, compliance breaches, or ethical concerns without fear of retaliation. Reports can be submitted through multiple channels: a dedicated email address monitored exclusively by the compliance function, a third-party anonymous reporting platform, or direct communication with the Chief Compliance Officer or any advisory board member. All channels are available 24 hours a day across all three jurisdictions.

Retaliation against any person who reports a concern in good faith is treated as a serious disciplinary matter warranting summary termination. This protection applies regardless of whether the reported concern is ultimately substantiated. Whistleblower reports are investigated by the compliance function with advisory board oversight. Where a report concerns senior management, the investigation is conducted directly by the advisory board with external legal support. Investigation outcomes and remedial actions are documented and reported to the board. We publish aggregate whistleblower statistics — number of reports received, categories, outcomes — in our annual governance disclosures.

Training & Certification

Compliance training is mandatory, assessed, and documented. Every Kaelo professional completes a minimum of 20 hours of compliance training annually, covering: AML/CFT awareness and case studies, sanctions compliance and screening procedures, conflicts of interest identification and management, data protection and client confidentiality, anti-bribery and corruption, market conduct and insider trading prevention, and jurisdiction-specific regulatory requirements. Training is delivered through a combination of in-person workshops, online modules, and scenario-based assessments.

Assessment is mandatory — completion of training modules without passing the associated assessment does not satisfy the training requirement. Pass rates and remediation requirements are tracked by the compliance function and reported to the advisory board. New joiners complete an intensive compliance induction programme within 30 days of start date. Compliance certification records are maintained for each employee and are available for regulatory inspection. Senior professionals with client-facing responsibilities complete additional role-specific compliance modules calibrated to their specific advisory activities and jurisdictional exposures.