Compliance

How the firm is structured

Pristine :

  • is an asset management firm, authorized and regulated by l’Autorité des marchés financiers (AMF) under the number GP-16000035,
  • is an independant partnership, owned by its directors of French nationality and tax residence,
  • doesn’t have any shareholder or subsidiary acting in a questionable or grey-listed jurisdiction (Malte, Chypre, Jersey, Guernesey, Île de Man, Caïmans, Virgin Island,..),
  • is a signatory of the Principles for Responsible Investment (PRI), which encourages the fight against tax evasion and corruption and advocates corporate ownership transparency.
  • is the first Fiduciaire in France to to have received the ISO 9001 Certification from Bureau Veritas.

Pristine’s eco-system is built upon :

 

  • a partial delegation of compliance and internal control (permanent control of 2nd level and periodic control) entrusted to an independant audit firm,
  • one public accountant firm and two independant statutory auditors,
  • commercial relationships with top tier French financial institutions, for both custody and banking services,
  • partnerships with regulated institutions, all supervised by either the AMF or the ACPR.

Fiducie is an onshore tool:

  • Fiducies, according to French Civil code, have to be declared to French administration and registered with the French tax autority, formalities that Pristine’s carries out itself.
  • Settlors and beneficiaries of fiducies are designated as bénéficiaires effectifs according to EU anti-money laundering Directive and to the French monetary and financial Code. They are subject to exhaustive KYC disclosure requirements, with a level of viligiance dependent of risks linked to the parties and to the transaction.

How we do business

Regulatory compliance and internal control are the structural elements of an activity of fiduciaire. This business can not exist wihtout such backbones as it would ultimately expose parties to an unacceptable reputational risk. Necessary conditions are therefore the transparency of the fiduciaire and the robustness of its internal processes.

Pristine embodies these notions at leadership level by putting its partners in charge of essential regulatory functions. I am myslef acting as Chief Compliance Officier (RCCI – Responsable du Contrôle et de la Conformité Interne), as well as TRACFIN correspondant, in charge of the declaration of suspicious activities. The two other partners of the firm are respectively deputy RCCI and Chief Risk Officer. Moreover, we are accompanied by a leading expert compliance firm.

Our internal organisation is also defined the involvement of each of our employees in the management of our policies and processes. Our code of conduct encompasses the sum of our governing principles. This code is formally accepted each year by each of our employees as a condition for employment.

Compliance and control imperatives extend to business partners of Pristine, which, acting as PSEE (Prestataires de Service Essentiels Externalisés) or provider of financial services regulated by a French regulator, are bound to conform to equivalent rules.

In this way, fiducie benefits from an operational framework which forms the basis for its righteous use.


Fiducie is a securing tool.
To work as such, it has to be managed by irreproachable actors.


 

Renaud Baboin
CEO of Pristine