Financial Crime Compliance Manual
Introduction
Dominion Insurance Services, Inc. and First Dominion Corporation (hereinafter “Dominion”) is committed to the highest standards of compliance with financial crime legislation and best practices in the jurisdictions in which we operate. This Financial Crime Compliance Manual (the “Manual”) has been endorsed by our Board of Directors and reflects our commitment to maintaining a strong compliance culture.
As a Lloyd’s coverholder, Dominion also seeks to maintain standards of financial crime compliance consistent with those expected of all business written into Lloyd’s, thereby supporting compliance by Lloyd’s underwriters.
This Manual is reviewed at least annually by Dominion’s Financial Crime Compliance Officer ("FCO") and approved by the Board. The FCO is responsible for communicating its contents to staff and ensuring appropriate training, monitoring, and enforcement.
Definitions
Financial Crime
Any act or omission that violates, or attempts to violate, applicable law, including but not limited to: United States Bank Secrecy Act (31 USC §§ 5311–5332); U.S. Executive Order 13224 and the Specially Designated Nationals and Blocked Persons List maintained by the Office of Foreign Assets Control ("OFAC"); United Kingdom Proceeds of Crime Act 2002; United Kingdom Terrorism Act 2000; United Kingdom Bribery Act 2010; and any other similar U.S. or U.K. statute, or applicable European Union, United Nations, or local regulation.
Financial Crime Compliance Officer ("FCO")
Refers to Lawrence D. Hilton.
FinCEN
The United States Financial Crimes Enforcement Network.
Trading Partner
An insurance carrier, managing agent, or other entity with whom Dominion places insurance business or from whom we hold delegated authority.
Relevant Person
Any Dominion director, officer, employee, contractor, consultant, or agent, whether permanent, temporary, or third-party.
We / Us / Our
Dominion.
You
A Relevant Person acting for or on behalf of Dominion.
Purpose
The purpose of this Manual is to:
Inform all Relevant Persons of the policies, procedures, and standards required to ensure compliance with applicable financial crime laws and regulations.
Set forth Dominion’s framework for identifying, preventing, detecting, reporting, and remediating financial crime risks.
Support compliance by our Trading Partners and safeguard the integrity of the financial system.
Money laundering, international sanctions, and bribery are the principal areas of financial crime risk that impact our business.
Governance & Oversight
Financial Crime Compliance Officer
The FCO is responsible for implementing effective procedures, monitoring compliance, and reporting to the Board. The FCO will:
Establish, maintain, and update financial crime procedures.
Receive and assess reports of suspicious activity.
Establish and oversee staff training programs.
Conduct periodic reviews and testing of compliance controls.
Report at least annually to the Board, and promptly in the event of material issues.
Liaise with Trading Partners, regulators, and law enforcement, subject to applicable confidentiality restrictions.
The FCO shall have appropriate seniority, resources, and authority to discharge these responsibilities, and the full support of the Board and senior management.
Board of Directors
The Board retains ultimate responsibility for financial crime compliance. The Board shall:
Review and approve this Manual annually.
Review any compliance reports generated by the FCO.
Provide oversight and resources to ensure Dominion meets its obligations.
Risk-Based Approach
Dominion adopts a risk-based approach to financial crime compliance. This requires:
Assessing risks related to customers, products, transactions, delivery channels, and geographic exposure.
Applying enhanced due diligence to higher-risk relationships or transactions.
Updating risk assessments as needed.
Training
Dominion requires that all Relevant Persons receive appropriate financial crime training, including Lloyd’s online training on UK Anti-Money Laundering, Sanctions, and Bribery, and FinCEN resources on U.S. obligations.
Training occurs at least biannually for Relevant Persons handling client funds or compliance duties.
The FCO monitors and records training completion.
Anti-Money Laundering (AML)
Money laundering is the process of disguising criminal property as legitimate funds. Dominion prohibits all forms of money laundering and requires the following obligations:
Do not engage in or facilitate any transaction that could involve criminal property.
Report immediately to the FCO if you know or suspect property constitutes criminal proceeds.
Make disclosures to the FCO without alerting the subject of the suspicion ( tipping off is prohibited ).
Follow internal reporting procedures to enable timely filing of Suspicious Activity Reports (SARs), as appropriate.
The FCO shall maintain a documented SAR process and retain SAR-related records for at least 5 years .
Sanctions Compliance
Dominion is committed to compliance with all applicable sanctions regimes, including those administered by OFAC (U.S.), HM Treasury (U.K.), the European Union, and the United Nations.
Dominion prohibits making funds, economic resources, or services available, directly or indirectly, to any sanctioned person, entity, or jurisdiction. The FCO shall ensure real-time sanctions screening procedures are maintained and regularly tested.
Staff Responsibilities
Disclose immediately to the FCO any suspicion of sanctions violations.
Ensure customers, transactions, and counterparties are screened against applicable sanctions lists.
Seek FCO guidance where the application of sanctions is uncertain.
Anti-Bribery & Corruption
Dominion prohibits all forms of bribery and corruption.
Red flags must be escalated to the FCO.
Any facilitation payments are strictly prohibited.
No Relevant Person may offer, give, solicit, or accept bribes.
Transfers of value to a public official requires prior written FCO approval.
Reasonable and proportionate gifts or hospitality are permitted if approved by the FCO.
Third-party due diligence is required for agents, brokers, consultants, and other intermediaries.
Record Keeping
Records may be retained electronically provided confidentiality, integrity, and accessibility are assured as follows:
Transaction records: retain for a minimum of 5 years after completion.
Customer due diligence: retain for a minimum of 5 years after the relationship ends.
SARs, sanctions screenings, and bribery investigations: retain for a minimum of 5 years after report/closure.
Monitoring, Audit & Testing
The FCO will oversee compliance monitoring at regular intervals.
Audit findings and remediation plans will be reported to the Board.
Biannual financial crime framework reviews shall be conducted.
Reporting Concerns
If you have any knowledge, suspicion, or concern regarding financial crime, you must report immediately to the FCO. Confidentiality will be maintained to the extent permitted by law. Retaliation against any Relevant Person making a good-faith report is prohibited.
This Manual has been initially approved by the Board of Directors and will be reviewed and reapproved annually on or before July 1st.
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