PAG GLOBAL FINANCIAL INSTRUMENTS GOVERNANCE FRAMEWORK (FIGF)

Prepared for Pacific Alliance Group (PAG) and Zarif Menon & Associates (ZMA)

Purpose

To establish governance standards, due diligence protocols, and risk management procedures for financial instrument transactions including SBLC, BG, LC, MTN and related structured finance instruments.

1.) Objective

This framework establishes the governance structure used by PAG and ZMA when reviewing, assessing, and engaging in financial instrument transactions. It ensures that all transactions meet international banking standards, compliance obligations, and risk management principles consistent with Tier‑1 family office practices.

2.) Scope

This framework applies to all proposed transactions involving:

  • Standby Letters of Credit (SBLC)

  • Bank Guarantees (BG)

  • Letters of Credit (LC)

  • Medium Term Notes (MTN)

  • Structured Trade Finance Instruments

  • Credit Enhancement Facilities

  • Project Finance Credit Instruments

3.) Governance Structure

The governance structure for financial instrument transactions within PAG is as follows:

7.) Transaction Structure Review

All proposed structures must be assessed to confirm:

  • Commercial purpose of the instrument

  • Real trade or project underlying the request

  • Market‑consistent issuance fees

  • Logical payment flows

  • Clear contractual responsibilities

4.) Core Governance Principles

PAG adopts the following core principles when reviewing financial instrument transactions:

  • Integrity – Transactions must involve legitimate counterparties and transparent structures.

  • Compliance – All transactions must comply with AML, KYC, FATF and international banking regulations.

  • Transparency – All parties must disclose their roles clearly.

  • Risk Management – Transactions must be screened for financial, legal and operational risk.

  • Non‑Circumvention – All intermediaries must be protected through proper contractual frameworks.

5.) Mandatory Documentation

Before PAG or ZMA participates in any financial instrument transaction, the following documentation must be obtained and reviewed:

  • Client Information Summary (CIS)

  • Corporate Registration Documents

  • Passport / Identification of Directors

  • Bank Account Confirmation

  • Draft Instrument Verbiage

  • Issuing Bank Details

  • Transaction Purpose Documentation

6.) Financial Institution Verification

The issuing financial institution must be verified through the following checks:

  • Regulatory license verification

  • SWIFT capability confirmation

  • Bank credit rating review

  • Jurisdiction risk review

  • Historical transaction track record

8.) Risk Identification

Transactions must be reviewed for potential red flags including:

  • Offshore shell issuers with no regulatory license

  • Excessive upfront fees

  • Absence of identifiable issuing bank

  • Claims of “private banking instruments” outside SWIFT system

9.) Compliance and Sanction Screening

All parties must undergo sanctions screening including:

  • FATF jurisdiction analysis

  • Politically Exposed Person (PEP) checks

  • Global sanctions database screening

  • AML compliance review

10.) Decision Process

Following due diligence, PAG/ZMA shall classify the transaction as:

  • Approved – Transaction meets governance standards

  • Conditional Approval – Additional verification required

  • Rejected – High risk or non‑compliant structure

11.) Role of ZMA

Zarif Menon & Associates shall act as governance and compliance gatekeeper for PAG‑related financial instrument transactions. ZMA may provide facilitation, advisory, or structuring support but shall not assume banking or financial liability for instrument issuance.

12.) Continuous Review

This governance framework shall be reviewed periodically to ensure alignment with evolving international banking practices and regulatory expectations.