Compliance & Regulatory Information

1. Regulatory Framework

MitomCash operates under the regulatory oversight of:

2. Registration and Licensing

3. Anti-Money Laundering (AML) Program

MitomCash maintains a comprehensive AML program in compliance with the Bank Secrecy Act and USA PATRIOT Act. Our program includes:

• Customer Identification Program (CIP): Verification of customer identity using government-issued documents
• Customer Due Diligence (CDD): Understanding the nature and purpose of customer relationships
• Enhanced Due Diligence (EDD): Additional scrutiny for high-risk customers
• Suspicious Activity Monitoring: Ongoing monitoring and reporting of suspicious transactions
• Record Keeping: Maintenance of required records for regulatory periods
• Employee Training: Regular AML training for all personnel

4. Know Your Customer (KYC) Requirements

To comply with KYC regulations, we collect and verify the following information:

5. Data Protection and Privacy Compliance

We comply with applicable data protection regulations, including:

• Gramm-Leach-Bliley Act (GLBA): Financial privacy and data security requirements
• Regulation S-P: Privacy notices and safeguarding customer information
• State Privacy Laws: CCPA, CPRA, and other state-specific requirements
• International Standards: GDPR compliance for European customers

6. Best Execution Policy

MitomCash is committed to seeking best execution for all client transactions. We consider multiple factors including price, speed, likelihood of execution, and total transaction cost. Our execution venues and counterparties are regularly reviewed to ensure optimal execution quality.

7. Conflicts of Interest

We maintain policies to identify, disclose, and manage conflicts of interest, including:

• Compensation arrangements and revenue sharing
• Proprietary trading and principal transactions
• Personal trading by employees
• Relationships with third-party service providers

Material conflicts are disclosed in our Form ADV Part 2A, available upon request.

8. Cybersecurity and Information Security

Our cybersecurity program includes:

• Risk Assessment: Regular evaluation of cybersecurity risks
• Access Controls: Multi-factor authentication and role-based access
• Encryption: Data encryption in transit and at rest
• Incident Response: Procedures for detecting and responding to breaches
• Vendor Management: Due diligence on third-party service providers
• Employee Training: Regular security awareness training

9. Business Continuity and Disaster Recovery

We maintain a comprehensive business continuity plan to ensure:

• Continuation of critical business functions during disruptions
• Protection of customer assets and data
• Timely communication with customers during emergencies
• Regular testing and updating of recovery procedures

10. Complaint Handling and Dispute Resolution

We maintain procedures for handling customer complaints and disputes:

• Prompt acknowledgment of complaints within 2 business days
• Fair and thorough investigation of all issues
• Written response within 30 days
• Escalation procedures for unresolved matters
• Access to arbitration through FINRA Dispute Resolution

11. Regulatory Examinations and Audits

MitomCash is subject to periodic examinations by regulatory authorities and undergoes annual independent audits. We cooperate fully with all regulatory inquiries and maintain comprehensive records as required by law.

12. Whistleblower Policy

We encourage reporting of potential violations of laws, regulations, or company policies. Our whistleblower policy provides:

• Confidential reporting channels
• Protection against retaliation
• Prompt investigation of reports
• Appropriate remedial action

13. Regulatory Disclosures

The following documents are available upon request or can be accessed through regulatory databases:

• Form ADV Part 1 & 2: Investment adviser registration and disclosure
• Form CRS: Customer Relationship Summary
• Privacy Notice: Information about our privacy practices
• Business Continuity Plan Summary: Overview of our BCP

14. Contact Our Compliance Department

For compliance-related questions, concerns, or to request regulatory documents: