1. Regulatory Framework

As a licensed Wertpapierinstitut, we operate under the supervision of the German Federal Financial Supervisory Authority (BaFin) and comply with:

2. Compliance Organization

Our compliance structure includes dedicated officers and departments:

Function	Responsibilities	Reporting
Compliance Officer	Overseeing regulatory compliance, policies, training	Directly to Management Board
Money Laundering Officer	AML/CFT compliance, suspicious activity monitoring	To BaFin and FIU Germany
Data Protection Officer	GDPR compliance, data security, privacy matters	To Management Board and authorities
Risk Management	Risk assessments, controls, mitigation strategies	To Management Board and BaFin

3. Key Compliance Areas

3.1 Anti-Money Laundering (AML)

Our comprehensive AML program includes:

• Customer Due Diligence (CDD) and Know Your Customer (KYC) procedures
• Enhanced Due Diligence (EDD) for high-risk clients
• Automated transaction monitoring systems
• Sanctions and PEP screening
• Annual AML training for all employees
• Regular independent audits

3.2 Market Conduct

We adhere to strict market conduct rules:

• Insider trading prohibitions and monitoring
• Market abuse prevention systems
• Conflicts of interest policy and register
• Best execution policy for client orders
• Transparent pricing and fee structures

3.3 Data Protection

In compliance with GDPR, we implement:

• Data protection by design and default
• Secure data processing protocols (encryption, access controls)
• Data protection impact assessments
• Data subject rights procedures
• Data breach notification protocols

4. Regulatory Reporting

We fulfill all reporting obligations to German and EU authorities:

Report Type	Frequency	Recipient
Transaction Reports (MiFID II)	Daily	BaFin
Suspicious Activity Reports	As needed	FIU Germany
Financial Statements	Annual	BaFin & Commercial Register
Capital Adequacy Reports	Quarterly	BaFin
AML Risk Assessment	Annual	Internal & BaFin (upon request)

5. Client Protection

We prioritize client protection through:

• Segregation of client assets from company funds
• Professional indemnity insurance coverage
• Transparent fee and commission disclosure
• Clear risk warnings and product suitability assessments
• Complaint handling procedures with escalation to BaFin

6. Compliance Monitoring

Our comprehensive monitoring program includes:

7. Whistleblowing

We maintain confidential reporting channels for compliance concerns:

8. Contact Information

Compliance Department
MEDAS factoring GmbH
Messerschmittstraße 4
80992 München
Deutschland
Email: [email protected]
Phone: +49 93 929382 81
BaFin-ID: 10126957