Our position
Zero tolerance
Palanca Bridge maintains a zero-tolerance position on bribery and corruption.
All engagements are conducted to FCPA, KYC, AML, and sanctions-screening standards, under U.S. law. Contracts are executed under U.S. law and priced in U.S. dollars.
Anti-bribery controls (FCPA)
- Anti-bribery training for all engagement leads.
- A written record of interactions with any public official.
- No facilitation payments.
Engagement acceptance and red flags
Engagement acceptance is governed by a written policy with defined red-flag triggers; every engagement passes a screen before an engagement letter is issued.
- KYC and beneficial-ownership diligence — on the client and, where relevant, on the counterparties in the transaction.
- Sanctions and PEP screening — OFAC, EU, and UN lists; PEP identification with defined enhanced-diligence steps.
- We decline intelligence, access, and non-public-information services; a request for them is a red-flag trigger.
Advisory fees only
Palanca Bridge charges advisory fees only. We do not accept commissions, success fees, finder's fees, percentage-of-deal compensation, or any contingent arrangement. The full perimeter of our practice is set out on our Legal & Disclaimers page.
Advisors and contributors
Advisors and contributors serve in a strictly non-operational capacity and do not act on behalf of Palanca Bridge in any official function. Contributors who hold or have held public office do so in a personal, non-operational advisory capacity only, provide no non-public information, and do not use official position, authority, or influence on behalf of Palanca Bridge or its clients. Any such advisory relationship is structured to comply with the U.S. Foreign Corrupt Practices Act and applicable law.
Walk-away discipline
We maintain contractual grounds on which we exit an engagement if compliance conditions deteriorate. Our Chief Compliance Officer has ultimate authority over engagement acceptance, escalation of red flags, and walk-away decisions.
Our four written policies
Four written policies form the backbone of our compliance program:
- Engagement Acceptance & Red-Flag
- Conflicts of Interest
- Confidentiality & Records Retention
- ABC/AML (anti-bribery and corruption / anti-money-laundering)
The four written policies are reviewed annually by retained external counsel.
Responsibility and questions
This policy is maintained under the authority of our Chief Compliance Officer, Tom Kayo. More on our compliance program is on the Compliance page. Questions about this policy can be sent to compliance@palancabridge.com.