Corporate Governance

Compliance & Governance

Operating globally under US jurisdiction while maintaining EU data sovereignty standards. Our compliance framework ensures legal certainty, data protection, and operational excellence across all jurisdictions.

This page outlines our commitment to regulatory compliance, security certifications, ethical business practices, and transparent governance structures.

Last Updated: February 12, 2026 Wyoming LLC, USA EU Infrastructure

01. Compliance Overview

FW Delta LLC operates under a comprehensive compliance framework that balances global operational agility with strict adherence to regional data protection and regulatory requirements.

US Legal Entity

Registered in Wyoming, USA. Governed by US commercial law, Wyoming LLC Act, and federal regulations. Provides flexibility, IP protection, and international scalability.

EU Data Residency

All client data processed on EU-based infrastructure (Germany, Finland). GDPR-compliant by design. No US cloud providers for personal data storage.

Hybrid Compliance Model

This structure allows us to combine the operational advantages of US incorporation (flexible contracts, lower overhead, international banking) with the data protection standards our European clients expect and require.

02. Corporate Governance Structure

FW Delta LLC maintains a lean, efficient governance structure appropriate for a location-independent professional services firm.

Management Structure

Managing Member: Fabian Weiss – Responsible for strategic direction, operations, and compliance oversight

Compliance Officer: Fabian Weiss – Ensures adherence to GDPR, export controls, and ethical standards

Data Protection Officer: Fabian Weiss – Point of contact for data subject rights and supervisory authorities

Operational Model

Remote-First: No physical offices. Global talent recruitment based on merit.
Agile Decision-Making: Flat hierarchy enables rapid response to market changes.
Client-Centric: Direct communication between decision-makers and clients.

03. Data Sovereignty & Infrastructure

100% EU Data Residency

We maintain a strict separation between legal entity jurisdiction and data processing location. All client data remains within the European Union at all times, processed on infrastructure located in Germany and Finland.

Technical Implementation:

Primary Infrastructure

Provider: Hetzner Online GmbH (Germany)
Locations: Falkenstein, Germany; Nuremberg, Germany; Helsinki, Finland
Certifications: ISO/IEC 27001:2022 certified Infrastructure, GDPR-compliant DPA

We utilize bare-metal dedicated servers and private networking. No shared cloud infrastructure. Full control over data processing environment.

Security Architecture

TLS 1.3 encryption for all data in transit
AES-256 encryption for data at rest
Encrypted daily backups with geographic redundancy
Dedicated firewall with strict ingress/egress rules
24/7 intrusion detection and monitoring

05. Security Standards & Certifications

We implement comprehensive technical and organizational measures in accordance with Art. 32 GDPR and industry best practices.

ISO/IEC 27001:2022

Infrastructure Provider

Information Security Management System via Hetzner Online GmbH

GDPR Compliant

Verified

Full compliance with EU General Data Protection Regulation

Standard Contractual Clauses

Implemented

EU Commission-approved SCCs for international data transfers

PCI DSS Level 1

Payment Processor

Payment card data handled exclusively by certified third parties

06. Tax & Fiscal Compliance

FW Delta LLC is a US tax resident and maintains full transparency with tax authorities in all operating jurisdictions.

US Tax Compliance

As a Wyoming LLC, we are subject to US federal taxation. We file annual tax returns with the IRS and maintain compliant accounting records in accordance with US GAAP principles.

IRS Form 1065 (Partnership Return) filed annually
Registered Agent in Wyoming for legal correspondence
Annual Report filed with Wyoming Secretary of State

International B2B Invoicing (Reverse Charge)

For B2B clients in the European Union, we apply the Reverse Charge Mechanism in accordance with Art. 196 EU VAT Directive.

How it works: Services are invoiced net (without VAT). The tax liability shifts to the recipient (your company). You report and pay VAT in your country.

Requirements: Valid VAT ID required for all EU B2B clients. We verify VAT IDs via VIES system.

Benefits: No VAT pre-financing needed. Simplified cross-border transactions. Improved cash flow.

Note: Swiss clients (non-EU) receive invoices according to Swiss VAT regulations. For B2C transactions, applicable consumer VAT may apply.

Transfer Pricing & Documentation

We maintain appropriate transfer pricing documentation and operate at arm's length in accordance with OECD guidelines, though as a single-entity LLC with no subsidiaries, complex transfer pricing scenarios do not typically arise.

07. Export Control & Trade Compliance

As a US entity providing technology services, we comply with US Export Administration Regulations (EAR) and OFAC sanctions programs.

Sanctions Screening

We do not conduct business with individuals or entities on the OFAC Specially Designated Nationals (SDN) List or other restricted party lists. All new client relationships undergo sanctions screening.

Export Classification

Software and technology we develop are classified under ECCN 5D992 (not subject to EAR) or EAR99 (low-level controls).

No controlled cryptography or military applications.

Dual-Use Technology

Projects involving potential dual-use applications undergo internal review before acceptance.

We do not develop weapons systems or surveillance technology for authoritarian regimes.

08. AML & KYC Procedures

We implement Know Your Customer (KYC) and Anti-Money Laundering (AML) procedures appropriate to our risk profile as a professional services provider.

Client Due Diligence

Identity verification for all new business relationships
Beneficial ownership identification for corporate clients
Sanctions and PEP (Politically Exposed Persons) screening
Ongoing monitoring for high-risk relationships

Suspicious Activity Reporting

While we are not a financial institution, we maintain internal procedures to identify and report suspicious transactions or activities to appropriate authorities if encountered. We do not process cash payments or cryptocurrency for services.

09. Code of Ethics & Business Conduct

We uphold the highest standards of ethical conduct in all business operations.

Anti-Bribery & Corruption

Strict adherence to the US Foreign Corrupt Practices Act (FCPA) and UK Bribery Act principles. Zero tolerance for bribery, kickbacks, or improper payments.

Diversity & Inclusion

Remote-first model enables global talent acquisition based on merit. No discrimination based on nationality, religion, gender, or background.

Environmental Responsibility

No physical offices reduce carbon footprint. EU infrastructure powered by renewable energy sources through Hetzner's green data centers.

Conflicts of Interest

Full disclosure of potential conflicts. We do not accept engagements that compromise our independence or client confidentiality.

10. Subprocessor Management

We maintain a limited list of carefully vetted subprocessors. All subprocessors are bound by GDPR-compliant Data Processing Agreements.

Hetzner Online GmbH

Infrastructure & Hosting

Germany (EU)

Server hosting, data storage, backup services

Safeguards: ISO/IEC 27001:2022 certified Infrastructure, GDPR DPA

Google Ireland Limited

Analytics (Optional)

Ireland (EU) / USA

Website analytics (only with user consent)

Safeguards: EU-US DPF, SCCs

Meta Platforms Ireland

Marketing (Optional)

Ireland (EU) / USA

Conversion tracking (only with user consent)

Safeguards: SCCs, Data Processing Terms

Change Notification: We will notify clients of any new subprocessors or changes to existing ones with at least 30 days' notice, allowing you to object if you have legitimate concerns.

11. Security Incident Response

We maintain documented procedures for identifying, responding to, and reporting security incidents and personal data breaches.

Incident Response Timeline

0-1 hour

Detection and initial assessment. Containment measures activated.

1-24 hours

Investigation and impact analysis. Affected systems isolated.

24-72 hours

Client notification (if affected). Supervisory authority notification (if required by GDPR). Remediation implementation.

Breach Notification Obligations

In the event of a personal data breach, we will notify the relevant supervisory authority within 72 hours (as required by Art. 33 GDPR) and affected data subjects without undue delay if high risk to rights and freedoms exists (Art. 34 GDPR).

12. Audits & Compliance Verification

We support transparency through regular audits and compliance assessments.

Internal Audits

Quarterly security reviews and vulnerability assessments
Annual GDPR compliance assessments
Continuous monitoring of access logs and security events

Client Audit Rights

Enterprise clients have the right to conduct audits of our data processing activities upon reasonable notice.

We provide audit reports, compliance documentation, and evidence of security controls upon request.

13. Compliance Contact & Reporting

For compliance inquiries, concerns, or to report potential violations:

Fabian Weiss

Compliance Officer & Data Protection Officer

fw@fwdelta.com

Whistleblower Protection

We encourage reporting of compliance concerns or ethical violations. Reports can be made confidentially and will be investigated promptly.

We prohibit retaliation against individuals who report concerns in good faith. All reports are treated with confidentiality to the extent possible.

Compliance Framework Summary

GDPR (EU)

Personal data of EU/EEA residents

Swiss FADP

Personal data of Swiss residents

CCPA (California)

California residents (if applicable)

US Export Control (EAR/ITAR)

Technology export restrictions

FW Delta LLC maintains a comprehensive, multi-jurisdictional compliance framework that ensures operational agility while meeting the highest standards of data protection, security, and ethical business conduct.

Compliance Questions?

Our Compliance Officer is available to discuss our governance framework, certifications, or specific compliance requirements.

Contact Compliance Officer