Compliance

Review Summary — Current Page (Key Issues)

Current issues identified:

  1. Outdated and vague references

    The existing page references the U.S. Patriot Act and Russian sanctions without clear relevance to ECM’s core services or regulatory framework; it lacks detail about specific compliance standards and regional regulatory context. 

  2. Insufficient structure & client guidance

    The language focuses on client “qualification” but doesn’t clearly outline compliance frameworks, internal controls, policies, or how ECM manages risk. 

  3. Lacks named policies and standards

    There are no references to AML/KYC policies, data protection, conflict-of-interest management, regulatory reporting, or compliance escalation processes.

  4. Does not reflect best practices

    A professional compliance page should convey regulatory alignment, internal governance, risk management, client protections, and standards the firm adheres to.

  5. No clear authority sources cited

    For credibility, the page should reference applicable laws/regulators (e.g., Barbados FSC, CBB, AML/CTF laws), where relevant. 

Recommended Page Structure & Content (Draft to Replace Current Text)

Compliance

Last Updated: December 22, 2025

Efficient Consulting & Management Inc. (“ECM”, “we”, “our”, “the Firm”) is a Barbados-based cross-border structuring and transaction management firm. We operate with the highest standards of integrity, legal conformity, and professional conduct. Our compliance framework is designed to meet all applicable local and international regulatory requirements and reflects a robust culture of risk-aware decision-making.

Our Compliance Principles

ECM’s compliance program is built on four core principles:

  1. Regulatory Alignment

    ECM fully complies with all applicable Barbados regulatory laws and administrative rules, including anti-money laundering (AML) and countering the financing of terrorism (CFT) requirements, financial reporting obligations, and relevant international standards. 

  2. Risk Management & Internal Controls

    We maintain documented internal controls, policies, and procedures to identify, assess, monitor, and mitigate regulatory, operational, and reputational risk.

  3. Transparency & Accountability

    Our policies are designed to ensure transparency in client engagements, strong governance, clear reporting channels, and an accountability-focused culture throughout the firm.

  4. Client Protection & Integrity

    ECM enforces rigorous client onboarding procedures that align with best practices in Know Your Client (KYC), Know Your Prospect (KYP), beneficial ownership reviews, and ongoing monitoring.

Governance & Oversight

ECM’s compliance framework is overseen by senior management and designated compliance officers. Responsibilities include:

  • Developing and updating compliance policies and procedures.

  • Ensuring ongoing regulatory monitoring and regulatory change management.

  • Training staff on compliance obligations and ethical obligations.

  • Reporting compliance matters internally and, where required, to relevant authorities.

Regulatory Frameworks We Follow

ECM aligns its compliance practices with the following frameworks and standards:

  • Barbados Regulatory Regime — including corporate reporting obligations, economic substance requirements, and tax residency rules. 

  • Anti-Money Laundering & CFT Laws — robust procedures for client identification, transaction monitoring, suspicious activity reporting, and record retention. 

  • International Best Practices — guidance from recognised regulatory regimes when applicable to cross-border activities.

Client Onboarding & Due Diligence

Before any engagement or service provision, clients and prospects must complete a structured compliance review. This includes:

  • Identity verification for individuals and beneficial owners.

  • Verification of corporate structure and authorized signatories.

  • Assessment of source of funds and purpose of engagement.

  • Alignment with AML/CFT policies and risk appetite standards.

No services are provided until compliance approval is confirmed.

Data Protection & Confidentiality

ECM maintains strict data protection, confidentiality, and privacy protocols consistent with applicable laws and internationally accepted standards. Sensitive client information is protected through secure systems, access controls, and retention policies.

Reporting & Whistleblowing

ECM supports transparent reporting of compliance concerns. Employees and stakeholders can confidentially report issues through designated internal channels. Matters are investigated promptly with appropriate corrective actions.

Training & Continuous Improvement

Regular compliance training is provided to all relevant personnel to ensure up-to-date knowledge of regulatory developments, internal policies, and areas of heightened risk.

Disclaimers

Information on this website is provided for general guidance only and does not constitute legal, financial, or investment advice. ECM’s compliance statements reflect our current policies and may be revised to reflect regulatory developments.

Contact & Reporting

If you have questions or require additional information about our compliance program, please contact:

65 Violet Circle, Oxnards, St. James, Bridgetown, Barbados | BB23019

📧 ssb@ecmbb.com