Compliance

1. Our Commitment to Compliance

Spry & Hodler Investment Group is committed to conducting business in full compliance with all applicable laws, regulations, and industry standards. Our compliance framework is designed to protect our clients, maintain the integrity of financial markets, and uphold the trust placed in us as stewards of investor capital.

We maintain a dedicated compliance team that monitors regulatory developments, implements controls, and ensures adherence across all areas of our operations — from cryptocurrency custody to agricultural asset management.

2. Regulatory Framework

Our operations are subject to oversight from multiple regulatory bodies, depending on the jurisdiction and asset class. Our compliance program addresses the requirements of:

• Securities Regulations: We comply with applicable securities laws governing the offer, sale, and management of investment products
• Financial Services Regulations: We maintain appropriate licenses and registrations required for investment management activities
• Cryptocurrency Regulations: We adhere to applicable virtual asset service provider (VASP) requirements, including registration, reporting, and custody standards
• Real Estate Investment Regulations: Our real estate operations comply with applicable property investment laws and fractional ownership regulations
• Agricultural Commodity Regulations: Our agricultural investments comply with commodity trading and agricultural investment regulations

3. Anti-Money Laundering (AML) Program

We maintain a comprehensive AML program designed to detect and prevent money laundering and terrorist financing. Our program includes:

Customer Due Diligence (CDD)

• Identity verification of all clients prior to account opening
• Assessment of customer risk profiles based on multiple factors
• Ongoing monitoring of customer activity and transactions
• Enhanced Due Diligence (EDD) for high-risk customers, including Politically Exposed Persons (PEPs)

Transaction Monitoring

• Automated systems to detect unusual or suspicious transaction patterns
• Real-time screening against global sanctions lists (OFAC, EU, UN)
• Blockchain analytics for cryptocurrency transactions to identify high-risk wallet addresses
• Threshold-based reporting for large transactions as required by law

Suspicious Activity Reporting

When suspicious activity is identified, our compliance team conducts a thorough investigation and files Suspicious Activity Reports (SARs) with the appropriate Financial Intelligence Unit (FIU) as required by applicable law.

4. Know Your Customer (KYC) Requirements

All clients must complete our KYC verification process before accessing investment services. This process includes:

We utilize industry-leading identity verification technology to process KYC applications securely and efficiently. Most verifications are completed within 24 hours.

5. Sanctions Compliance

We maintain strict compliance with international sanctions programs. Our sanctions compliance program includes:

• Screening all customers and counterparties against global sanctions lists at onboarding and on an ongoing basis
• Monitoring transactions for connections to sanctioned jurisdictions, entities, and individuals
• Blocking or rejecting transactions that violate applicable sanctions requirements
• Regular updates to screening systems as sanctions lists are modified
• Cryptocurrency-specific sanctions screening using blockchain analytics tools

6. Data Protection and Privacy

Our compliance program includes robust data protection measures in accordance with applicable privacy laws including the GDPR, CCPA, and other relevant regulations. Key measures include:

• Data Protection Impact Assessments (DPIAs) for high-risk processing activities
• Appointed Data Protection Officer (DPO) responsible for privacy compliance
• Regular privacy audits and employee training
• Incident response procedures for data breaches
• Clear data subject rights processes for access, rectification, and erasure requests

For detailed information on how we handle personal data, please refer to our Privacy Policy.

7. Internal Controls and Governance

Compliance Organization

• Chief Compliance Officer (CCO): Reports directly to the Board of Directors with full independence from business operations
• Compliance Committee: Meets quarterly to review compliance matters, regulatory changes, and program effectiveness
• Internal Audit: Independent audit function conducts annual reviews of compliance controls

Policies and Procedures

• Comprehensive compliance manual updated at least annually
• Code of Ethics and Personal Trading Policy for all employees
• Conflicts of Interest Policy with mandatory disclosure requirements
• Gifts and Entertainment Policy
• Information Barrier (Chinese Wall) procedures between departments

8. Employee Training

All employees undergo mandatory compliance training, including:

• AML/KYC training at onboarding and annually thereafter
• Sanctions compliance awareness
• Data protection and cybersecurity training
• Code of Ethics and insider trading prevention
• Role-specific compliance training for investment, operations, and client-facing staff

9. Whistleblower Protection

We encourage the reporting of suspected compliance violations, unethical conduct, or illegal activity. Our whistleblower program provides:

• Confidential and anonymous reporting channels
• Protection against retaliation for good-faith reports
• Independent investigation of all reports
• Regular communication to staff about the availability of reporting mechanisms

Reports can be submitted confidentially to compliance@spryandhodler.com or through our anonymous reporting hotline.

10. Regulatory Examinations and Audits

We cooperate fully with all regulatory examinations and maintain organized records to facilitate efficient review processes. Our compliance infrastructure supports:

• Comprehensive recordkeeping in accordance with regulatory retention requirements
• Timely responses to regulatory inquiries and information requests
• Periodic self-assessments and gap analyses
• External compliance audits conducted by independent third-party firms

11. Contact the Compliance Team

For compliance-related inquiries, regulatory concerns, or to report potential violations: