ES
Legal document

Client Grievance and Resolution Policy

Last updated: August 17, 2026

1. Purpose

The Dinaria LLC (“Dinaria”) Complaints and Resolution Policy establishes a structured and transparent framework to ensure that every complaint, concern or dispute raised by clients, users or business partners is handled in a timely, consistent and fair manner. The primary objective of this policy is to identify and resolve issues proactively, foster client trust, and ensure full compliance with the applicable regulatory obligations governing Money Services Businesses (MSBs) under United States and international financial regulations.

2. Scope

This policy applies to every complaint submitted to Dinaria, whether initiated by an individual client, an institutional client, a third-party service provider, a financial institution or a governmental/regulatory authority. It covers all services provided directly by Dinaria or through its affiliated entities, including but not limited to:

  • Payment processing and funds transfer services
  • Client onboarding and KYC verification
  • Currency exchange and conversion operations
  • Technical support and system-related assistance
  • Compliance operations and regulatory reporting

3. Definition of a Complaint

A complaint is any written, verbal or electronic expression of dissatisfaction or concern from a client, partner or stakeholder regarding Dinaria's services, operations, conduct or policies, in which the complainant reasonably expects a formal response, explanation or corrective action.

4. How to Submit a Complaint

Complaints must be submitted in writing, by email, to support@dinaria.com.

To ensure efficient and appropriate handling, the complaint should include the complainant's full name, contact information, a reference to any relevant account or transaction, and a concise but detailed description of the matter.

5. Acknowledgment and Response Times

Complaints will be formally acknowledged in writing within one (1) business day of receipt. The acknowledgment will include a unique reference number and the name of the person handling the complaint.

A full written response detailing the outcome, the findings and any applicable resolution will be provided within fifteen (15) business days.

Where that timeframe cannot be met, the complainant will be notified in writing of the reason for the delay and the date by which a final response can be expected.

6. Complaint Handling Procedure

  1. The complaint is recorded in Dinaria's internal complaints register and assigned a unique reference number.
  2. The Compliance Officer or a designated representative initiates a preliminary review within 48 hours.
  3. All relevant transaction records, communications and evidence are examined.
  4. Where necessary, clarification or additional documentation is requested from the complainant.
  5. A written resolution is documented and delivered to the complainant, including the rationale and any corrective action.
  6. All complaint documentation is retained for a minimum of five (5) years, in line with audit and regulatory standards.

7. Escalation Process

If the complainant is not satisfied with the initial resolution, they may formally request escalation to Dinaria's senior management. Upon escalation, the complaint will be reassessed and a final written decision will be issued within ten (10) business days.

Where the complaint concerns a service provided to you by a regulated third-party provider, Dinaria will escalate it to that provider and keep you informed of its progress and outcome.

Where complaints involve legal exposure, regulatory risk or reputational concerns, Dinaria reserves the right to consult external legal counsel or compliance specialists.

8. Confidentiality

All complaints will be treated with the highest level of confidentiality. Personally identifiable information and case details will be accessible only to the personnel directly involved in the resolution process, and will be protected in accordance with applicable privacy and data protection laws, including the General Data Protection Regulation (GDPR) and United States federal and state privacy statutes.

9. Monitoring and Reporting

The Compliance Department will maintain complaint metrics and produce internal reports analysing:

  • Emerging trends in the nature and frequency of complaints
  • Root causes of recurring or systemic issues
  • Preventive and corrective measures implemented

These reports will be reviewed periodically by Dinaria's executive management and shared with regulators or auditors where required.

10. Policy Review

This policy will be reviewed and updated at least annually, or earlier if triggered by:

  • Material changes in applicable regulations
  • Findings from internal or external audits
  • Substantive operational, product or risk developments

All amendments must be reviewed and approved by Dinaria's Compliance Officer and Managing Member before adoption.

11. Non-Retaliation Statement

Dinaria guarantees that no complainant will be subjected to retaliation, discrimination or disadvantage for submitting a complaint in good faith. All feedback is regarded as an opportunity to improve our services, processes and client experience.