Policy Version Approval

I've reviewed the proposed changes to the Latin America compliance thresholds. The adjustment from 95% to 92% is reasonable given the regional market conditions and regulatory environment in Brazil.

Key points reviewed:

• São Paulo office override capability aligns with local regulatory requirements
• BRL currency conversion rates are accurate as of current market rates
• Enhanced escalation rules provide appropriate safeguards for large transactions

The changes maintain our overall risk posture while providing necessary operational flexibility. Approved for implementation.

From a compliance perspective, these changes are well-structured and maintain our regulatory obligations.

Compliance review findings:

• ✅ SOX compliance maintained with enhanced audit logging
• ✅ Anti-money laundering thresholds remain appropriate
• ✅ Regional regulatory requirements for Brazil properly addressed
• ✅ Escalation procedures meet internal control standards

Recommendation: Monitor the 92% threshold for 60 days and review if further adjustments are needed based on actual compliance rates.

Thank you for including regional input on these changes. The adjustments are much needed and will significantly improve our operational efficiency in the São Paulo office.

Regional context:

• The 92% threshold better reflects Brazilian banking system delays
• Weekend/holiday approval workflows address local business calendar differences
• BRL currency volatility handling is now more robust

Our team has tested the new override capability and it works seamlessly with local processes. Full approval from LATAM region.

Next steps: I'll coordinate with the São Paulo team to ensure smooth transition when the policy goes live.