Service, Regulatory & Professional Boundary

1. Purpose

This document explains what Afilcorp may provide, what it does not provide and how FO-EGP, TCSP services, professional advisers and Third-Party Providers remain legally distinct.

2. Afilcorp’s role

Subject to Engagement Terms, Afilcorp may provide non-regulated work including:

• family and corporate governance architecture;

• authority, reserved-matters, ownership, continuity and evidence registers;

• operating-model and responsibility mapping;

• policy and document administration;

• institutional-readiness information coordination;

• corporate and statutory administration;

• remediation and implementation registers;

• cross-border project coordination; and

• FO-EGP membership and periodic governance review.

The precise scope depends on the accepted engagement.

3. FO-EGP

3.1 FO-EGP is a methodology and membership framework for governance, evidence, coordination and recurring review.

3.2 FO-EGP is not:

• a legal person;

• a financial product;

• an investment or pooled arrangement;

• a regulated market;

• a bank or payment service;

• a licence or accreditation; or

• a guarantee of access to a Third-Party Provider.

3.3 The family, board, trustee, committee or authorised management retains its decision-making responsibility.

4. TCSP services

4.1 Where current official verification confirms Afilcorp Capital Pte Limited’s TCSP licence, Afilcorp may carry on the trust or company services expressly accepted in writing and lawfully within the licence.

4.2 Depending on actual scope and law, trust or company services may include forming legal persons, providing registered-office or correspondence-address services, acting or arranging another person to act in specified company or trust roles, or other services falling within the statutory definition.

4.3 Afilcorp will not claim to provide a trust or company service outside the verified licence or Engagement Terms.

4.4 Acting as trustee, nominee shareholder, director or similar office-holder is not implied by the Website and requires separate express acceptance, due diligence, terms and legal capacity.

5. AML/CFT duties

5.1 CDD and record-keeping duties under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance are compliance obligations applicable to a TCSP licensee.

5.2 Those duties are not a general AML-advisory licence and do not authorise regulated financial activity.

5.3 Afilcorp may request ownership, control, purpose, source and identity information to comply with law and risk controls.

5.4 Afilcorp’s collection or coordination of KYC/KYB information does not certify that a client or structure is compliant or acceptable to another institution.

6. No securities or investment activity

Afilcorp does not, through the Website or FO-EGP:

• deal in or arrange securities, futures, leveraged foreign exchange or virtual assets;

• provide investment advice or discretionary management;

• operate a trading platform, exchange, brokerage or liquidity service;

• issue or distribute financial products;

• manage portfolios or funds; or

• provide investment research or recommendations.

Governance of an investment decision process is distinct from investment advice.

7. No banking, payment or custody

Afilcorp does not:

• accept deposits;

• provide bank accounts or credit;

• issue e-money or stored value;

• process, acquire or settle payments;

• hold client money or assets;

• act as custodian, depositary or escrow agent; or

• guarantee banking, EMI, PSP or provider onboarding.

Afilcorp may organise an information pack or coordinate communications. The institution decides independently.

8. No legal, tax, accounting, audit or valuation opinion

Afilcorp is not presented as:

• a law firm;

• a tax adviser;

• an accounting practice;

• an audit or assurance practice;

• a valuation practice; or

• an actuarial practice.

Afilcorp may identify questions, maintain records and coordinate information. Conclusions remain with separately appointed qualified professionals.

9. No regulatory representation

Afilcorp does not:

• act as a regulator or licensing authority;

• make a regulatory determination;

• guarantee authorisation or registration;

• represent that it has special access or influence;

• bind a regulator; or

• describe its methodology as regulator-approved.

Administrative support for an application or response does not transfer responsibility for the application, facts or legal analysis.

10. Client and board responsibility

The client remains responsible for:

• its purpose, business model and activities;
• decisions;
• ownership and beneficial ownership;
• legal and regulatory compliance;
• tax, accounting and reporting;
• accuracy of information;
• implementation;
• selection and supervision of providers;
• client money and assets;
• board, trustee and fiduciary duties;
• obtaining specialist advice.

11. Third-Party Providers

Third-Party Providers act independently and contract directly unless an express written arrangement says otherwise.

Afilcorp does not guarantee:

• appointment;
• acceptance;
• pricing;
• service quality;
• permission;
• timing;
• continuation;
• outcome.

12. Institutional readiness

“Institutional readiness”, “banking readiness”, “licensing readiness” and similar expressions mean the organisation of governance, facts, documents, evidence, dependencies and response processes.

They do not mean:

• approved;
• licensed;
• bankable;
• accepted;
• certified;
• compliant in every respect;
• guaranteed to succeed.

Use these expressions only with the stated qualification.

13. Cross-border work

Afilcorp may coordinate a common facts and responsibility framework across jurisdictions.

It does not provide a universal legal, tax or regulatory conclusion.

Local advice remains necessary for:

• legal validity;
• tax residence;
• permanent establishment;
• trust and succession law;
• investment regulation;
• sanctions;
• data transfer;
• beneficial ownership;
• employment;
• accounting and audit.

14. Research and publications

Afilcorp research is general information.

Publications may include governance recommendations and summaries of official materials. They are not legal opinions, tax opinions, audit reports, investment research or regulator-approved standards.

Pending measures must be identified as pending.

15. Restricted jurisdictions and users

Afilcorp will not accept work that is unlawful, prohibited by sanctions, beyond its permissions or outside its risk appetite.

Do not publish a blanket “no US persons” policy or regulator-specific exclusion unless the policy is genuinely adopted, defined and enforced through intake and engagement procedures.

16. No certification

Afilcorp does not certify that a person, structure, policy, system or transaction:

• complies with all law;
• is audit-ready;
• is bank-approved;
• is regulator-approved;
• is tax-efficient;
• is fit for investment;
• is free from risk.

Any formal certification or assurance must come from an appropriately appointed provider.

17. Changes and escalation

The boundary must be reassessed if the facts, services, jurisdictions, users, remuneration, delegated authority or provider relationships change.

Any uncertainty should be escalated before work continues.

18. Engagement terms

This public boundary is supplemented by the Engagement Terms. The Engagement Terms may narrow the scope but cannot create a permission that Afilcorp does not lawfully hold.