Compliance
Compliance is the operating system.
Every Palanca Bridge engagement is built on U.S. compliance standards from the first step. Participation must be profitable — and beyond reproach.
- FCPA
- KYC / AML
- OFAC / EU / UN sanctions
Chief Compliance Officer
Chief Compliance Officer — Tom Kayo.
Palanca Bridge has a formal Chief Compliance Officer role held by Managing Partner Tom Kayo. The CCO holds the ACCPA Anti-Money-Laundering Compliance designation and has ultimate authority over engagement acceptance, escalation of red flags, and walk-away decisions. The CCO reports to the Palanca Bridge Corp board.
Governance
Governance architecture
The Chief Compliance Officer holds engagement-acceptance authority and final sign-off. The counterweights that make this concentration workable in a two-principal firm are structural, not discretionary:
DRAFT — awaiting client's verbatim copy (addendum: Part B, /compliance governance architecture)
Mandatory second review
The Managing Partner Europe conducts a mandatory second review on above-threshold declinations and European counterparty exposure.
Countersignature protocol
Compliance Clearance Letters carry a countersignature protocol, so no signature product depends on a single principal. Every signed clearance carries two-principal QA acknowledgment.
External governance and counsel lane
Retained external counsel and a fractional CFO participate in a standing quarterly external-governance meeting. Escalated flags are routed through a counsel lane.
Deadlock resolution
A deadlock-resolution clause provides for escalation and a cooling-off period, followed by an external tiebreaker. The CCO’s compliance-acceptance authority is carved out.
Frameworks
Frameworks we apply
FCPA — anti-corruption diligence and controls.
KYC / AML — identity, beneficial ownership, and anti-money-laundering screening.
Sanctions — OFAC, EU, and UN sanctions and PEP screening.
Local licensing — verification that local execution partners are properly licensed in their jurisdiction.
Our four written policies
DRAFT — awaiting client's verbatim copy (addendum: Part B, /compliance four written policies)
- Engagement Acceptance & Red-Flag
- Conflicts of Interest
- Confidentiality & Records Retention
- ABC/AML
Each policy is reviewed annually by retained external counsel.
Compliance Program
Six controls on every engagement
Engagement acceptance — written policy with defined red-flag triggers; every engagement passes a screen before an engagement letter is issued.
KYC and beneficial-ownership diligence — on the client and, where relevant, on the counterparties in the transaction.
Sanctions and PEP screening — OFAC, EU, and UN lists; PEP identification with defined enhanced-diligence steps.
FCPA controls — anti-bribery training for all engagement leads; written record of interactions with any public official; no facilitation payments.
Conflicts and independence register — engagements screened against a maintained register; any conflict disclosed to the client before contracting.
Walk-away discipline — contractual grounds on which we exit an engagement if compliance conditions deteriorate.
Perimeter of our practice
Palanca Bridge charges advisory fees only. We do not: take commissions or success fees; act as a broker-dealer or securities intermediary; lobby or represent foreign governments (no FARA-registrable activity); provide legal advice or engage in the unauthorized practice of law; navigate CFIUS reviews on behalf of clients; or bill by the hour to end clients. Where specialized services are required, we work alongside licensed U.S. attorneys, registered broker-dealers, immigration counsel, and other qualified professionals.
Downloads
Compliance Program one-pager
Download the Compliance Program one-pager (PDF):
- EnglishPDF forthcoming — available on request from compliance@palancabridge.com
- PortuguêsPDF forthcoming — available on request from compliance@palancabridge.com
Under NDA
Vendor-Onboarding Pack (request access)
Institutional buyers and DFI procurement officers may request the vendor-onboarding pack: the four written policies, the SKU catalog with exclusions, the tier framework with Excluded list, the countersignature protocol, and the governance calendar. Provided under our standard NDA.
Our compliance and integrity practice is led by our Chief Compliance Officer, Tom Kayo, who holds the ACCPA Anti-Money-Laundering Compliance designation.
Governance calendar
Annual review of the four written policies by retained external counsel. Annual CCO review of the Excluded Markets list, with event-driven updates within ten business days. Rate-card and financial-model refresh at Days 61–90 and again at Months 4–6.
How we work
How we work
Findings are documented to institutional standards, with sources stated and limitations disclosed. Contracts are executed under U.S. law and priced in U.S. dollars. Where a specific counterparty, partner, or jurisdiction requires it, compliance and integrity screening runs first — no engagement letter is issued until the initial screen clears.