Compliance
Compliance framework
MatchCut operates a documented compliance framework covering our obligations as an Australian Financial Services Licence holder, the operation of our funds, and our dealings with investors and counterparties. Our framework includes a compliance plan, a risk management system, and periodic internal and external review.
Anti-money laundering and counter-terrorism financing
MatchCut is a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006(Cth) (the “AML/CTF Act”). We have an AML/CTF program that includes customer identification and verification, ongoing customer due diligence, transaction monitoring, suspicious matter reporting, and staff training. We cooperate with AUSTRAC in the performance of its functions under the AML/CTF Act.
Sanctions
We screen investors, counterparties, and production participants against Australian and applicable international sanctions lists. We will not enter into or continue a relationship where doing so would contravene sanctions laws.
Conflicts of interest
MatchCut maintains a conflicts of interest policy that requires the identification, recording, and management of actual, potential, and perceived conflicts. Material conflicts are disclosed to affected parties. Where a conflict cannot be adequately managed through disclosure and controls, we will decline to act.
Whistleblower protection
MatchCut supports and protects whistleblowers in accordance with Part 9.4AAA of the Corporations Act. Eligible whistleblowers may make disclosures to our designated whistleblower officer, the Audit and Risk Committee, ASIC, or another eligible recipient. Disclosures may be made on a confidential basis and are protected from retaliation.
Breach reporting
Significant breaches of our AFSL obligations are reported to ASIC as required by section 912DAA of the Corporations Act. Breaches of AML/CTF obligations are reported to AUSTRAC as required.
Record keeping
We retain records of our financial services business, fund operations, and client interactions for the minimum periods required by the Corporations Act, the AML/CTF Act, the Privacy Act, and applicable taxation laws.