Our Compliance Commitments
We operate with integrity, transparency, and accountability across every jurisdiction we serve.
Effective date: June 4, 2026
As a fintech advisory firm operating across Latin America’s regulated financial markets, Divergint holds itself to the same standards of integrity that we help our clients build. The summaries below describe the principles that govern how we work. They are policy statements, not legal advice, and may be supplemented by more detailed internal procedures.
KYC / AML Policy — Know Your Customer & Anti-Money Laundering
Divergint is committed to preventing its services from being used to facilitate money laundering, terrorist financing, or other financial crime. Before and during an engagement, we apply risk-based due diligence to understand who our clients are, the nature of their business, their ownership and control structure, and the source of the funds involved. We screen relevant parties against applicable sanctions, politically-exposed-persons, and adverse-media sources, and we apply enhanced scrutiny to higher-risk relationships.
We will decline or discontinue any engagement where we cannot satisfy ourselves as to a client’s identity or legitimacy, where the purpose appears unlawful, or where continuing would conflict with applicable AML/CFT obligations. Where required, we cooperate with competent authorities and make any reports the law demands. These practices are aligned with FATF recommendations and the local frameworks (such as Colombia’s SARLAFT and UIAF requirements) in the markets where we operate.
ESG Policy — Environmental, Social & Governance
We believe responsible business and good advice go together. Environmentally, we operate as a lean, predominantly remote firm and seek to minimize the footprint of our operations and travel. Socially, we are committed to fair, respectful, and inclusive treatment of our people, clients, and partners, free from discrimination or harassment, and to advancing financial access and inclusion across Latin America through our work. In governance, we maintain clear accountability, manage conflicts of interest, protect client confidentiality and data, and hold ourselves to the regulatory and ethical standards we advise our clients to meet.
Anti-Bribery & Anti-Corruption Policy
Divergint maintains a zero-tolerance approach to bribery and corruption in all its forms, whether involving public officials or the private sector, and whether committed directly or through third parties. We do not offer, promise, give, solicit, or accept any bribe, kickback, or improper advantage to obtain or retain business or to influence any decision, and we do not make facilitation payments.
We exercise care with gifts, hospitality, and engagements that could create an actual or perceived conflict of interest, and we conduct appropriate diligence on partners and intermediaries acting on our behalf. We comply with applicable anti-corruption laws — including local statutes and, where relevant, the U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act — and we expect the same standard from those we work with. Concerns may be raised confidentially using the contact below.
Questions about our compliance commitments? Contact legal@divergint.co.