Legal & Compliance

# Legal Disclosures & Compliance

Cresta Trust & Geneva Mercantile Consortium is committed to full transparency and regulatory integrity. This page outlines our regulatory framework, compliance obligations, and your rights as a client of an FSC-licensed international financial institution.

## FSC Licensing & Regulatory Authority

Swiss Financial Market Supervisory Authority (FINMA) — Reg. No. CH-660.4.982.371-8

Cresta Trust & Geneva Mercantile Consortium (hereinafter “CTGMC”) is incorporated in the Swiss Confederation under the Code of Obligations (Company Registration No. CH-660.4.982.371-8) and licensed by the Swiss Financial Market Supervisory Authority (FINMA) under Licence No. FINMA-B-00312/2014 to conduct banking business, including acceptance of deposits, cross-border payment services, and private wealth management.

FINMA is the independent financial market regulator for Switzerland. CTGMC operates under continuous FINMA supervision and is subject to regular examination, prudential reporting, and compliance audits. Our registered office is located at Quai des Bergues 29, 3rd Floor, 1201 Genève, Switzerland.

Switzerland is a member of the Committee of Experts on the Evaluation of Anti-Money Laundering Measures (MONEYVAL) and is aligned with FATF recommendations. Switzerland is included on the OECD Global Forum's list of jurisdictions committed to the international standard for tax transparency and exchange of information.

Compliance Statement: CTGMC maintains FINMA licensing in good standing and undergoes annual independent audits. Copies of our licence, certificate of incorporation, and audited financial statements are available to verified clients upon written request to compliance@ctgmc.ch.

## Know Your Customer (KYC) & Anti-Money Laundering

FIAMLA 2002 — FSC AML/CFT Guidelines — FATF 40 Recommendations

CTGMC is subject to the Financial Intelligence and Anti-Money Laundering Act 2002 (FIAMLA) and the regulations issued thereunder, as well as the FSC’s AML/CFT Guidelines. We are required to identify and verify all clients, understand the nature and purpose of business relationships, and monitor transactions on an ongoing basis.

What this means for you: To open an account, all applicants must complete our KYC onboarding process. We collect full legal name, date of birth, residential address, nationality, source of funds declaration, and government-issued photo identification (passport or national ID). Proof of address not older than 90 days is also required. For corporate accounts, we require certified copies of incorporation documents, register of directors and shareholders, and a group structure chart where applicable.

CTGMC operates a three-level KYC model: Level 1 (basic identity + email verification), Level 2 (full identity document review and approval), and Level 3 (identity plus proof of address + enhanced due diligence for clients above defined transaction thresholds). Transfer limits increase at each KYC level.

CTGMC will file Suspicious Transaction Reports (STRs) with the Money Laundering Reporting Office Switzerland (MROS) where there are reasonable grounds to suspect money laundering, terrorist financing, or other financial crime. We are legally prohibited from tipping off any person that such a report has been or may be made.

Compliance Statement: CTGMC maintains a robust AML/CFT programme including a dedicated Compliance Officer, documented risk-based procedures, staff training, independent audits, and transaction monitoring systems. All client relationships are subject to ongoing review.

## Data Privacy & Confidentiality

Swiss Federal Act on Data Protection (FADP) — GDPR-Aligned Standards

CTGMC is bound by the Swiss Federal Act on Data Protection (FADP) of Switzerland, which is broadly aligned with the principles of the EU General Data Protection Regulation (GDPR). We are registered with the Federal Data Protection and Information Commissioner (FDPIC) as a data controller.

We collect personal data solely for the purpose of providing banking services, fulfilling our legal and regulatory obligations, and communicating with you about your account. We do not sell or share your personal data with third parties for marketing or commercial purposes.

Client confidentiality is a core principle of CTGMC. Information about your accounts, balances, and transactions is kept strictly private and will not be disclosed to any third party except: (a) where required by applicable law or a valid court order, (b) with your express written consent, or (c) to our licensed correspondent banking partners as necessary to execute your instructions.

You have the right to access, correct, and in certain circumstances request deletion of your personal data. To exercise these rights or obtain our full Privacy Policy, contact privacy@ctgmc.ch.

Compliance Statement: CTGMC implements end-to-end encryption, multi-factor authentication, and role-based access controls to protect all personal data. Our information security framework is aligned with ISO/IEC 27001 and subject to annual independent review.

## International Wire Transfers & SWIFT

SWIFT Membership — Correspondent Banking Framework — FATF Recommendation 16

CTGMC processes international wire transfers via the SWIFT network (Society for Worldwide Interbank Financial Telecommunication). All outbound international transfers include full originator and beneficiary information in compliance with FATF Recommendation 16 (the “Travel Rule”) and applicable Switzerland regulations.

Transfers are processed through our correspondent banking network across USD, EUR, GBP, and CHF corridors. Transfer timelines depend on the destination jurisdiction: typically 1–2 business days within our primary corridors, and 2–5 business days for other international destinations.

Transfer Limits by KYC Level: Level 1 — up to €5,000/transaction; Level 2 — up to €50,000/transaction; Level 3 — up to €500,000/transaction (subject to compliance review for amounts above €100,000). Specific limits may be adjusted based on account history and enhanced due diligence outcomes.

CTGMC reserves the right to delay, reject, or reverse transactions where there are compliance concerns, sanctions screening matches, or insufficient supporting documentation for the stated purpose of the transfer.

Compliance Statement: CTGMC screens all transactions against OFAC, UN, EU, and HM Treasury sanctions lists in real time. Transactions involving sanctioned individuals, entities, or jurisdictions are blocked and reported to the relevant authorities.

## Risk Disclosures & Important Notices

FSC Investment Disclosure Requirements — General International Banking Risk Notice

Deposit Risk: CTGMC is not a member of any national deposit guarantee scheme equivalent to the FDIC (USA) or FSCS (UK). Client deposits are not covered by a government-backed deposit insurance programme. Deposits are protected by the institution’s own capital adequacy, FSC prudential supervision, and sound banking practices.

Investment Risk: Any investment products, fixed deposit schemes, or wealth management services offered through CTGMC carry risk. Past performance is not indicative of future results. The value of investments may fall as well as rise, and you may receive back less than you invest. CTGMC does not provide investment advice regulated under any national financial advisory framework unless explicitly stated.

Currency Risk: Multi-currency accounts and cross-border transfers expose clients to foreign exchange fluctuations. CTGMC does not guarantee exchange rates and is not liable for losses arising from currency movements.

International Banking Notice: Banking with an international institution may have tax implications in your country of residence or domicile. CTGMC does not provide tax advice. Clients are responsible for ensuring compliance with all applicable tax laws in their home jurisdictions, including reporting requirements for foreign financial accounts (e.g., FATCA, CRS, FBAR).

Compliance Statement: CTGMC participates in the OECD Common Reporting Standard (CRS) automatic exchange of financial information programme and may report account information to the tax authorities of clients’ countries of tax residence where required by applicable law.

## Complaints Procedure

FSC Consumer Grievance Framework — Internal Dispute Resolution Policy

CTGMC is committed to resolving client complaints promptly, fairly, and transparently. If you have a concern about any aspect of our service, please follow the procedure below:

Step 1 — Contact Client Services: Submit your complaint in writing to complaints@ctgmc.ch or via the secure message centre in your client portal. Include your account number, a clear description of the issue, and the resolution you are seeking. We will acknowledge receipt within 2 business days.

Step 2 — Internal Review: Our Compliance team will investigate and provide a substantive written response within 15 business days. Complex cases may require up to 30 business days; we will notify you if additional time is required.

Step 3 — External Escalation: If you are not satisfied with our response, you may refer your complaint to the Swiss Financial Market Supervisory Authority (FINMA) at finma.ch or call +41 31 327 91 00.

Compliance Statement: CTGMC maintains a formal complaints register and reports complaint statistics to the FSC as required. We are committed to using complaints data to improve our services and processes.

These disclosures were last reviewed and updated in April 2026. For compliance enquiries, contact compliance@ctgmc.ch or call +41 22 909 4400. Cresta Trust & Geneva Mercantile Consortium — Reg. No. CH-660.4.982.371-8, Licensed by the Swiss Financial Market Supervisory Authority (FINMA) (FINMA-B-00312/2014).