The year 2024 marked a period of rapid expansion for the GIFT City IFSC ecosystem, with several ambitious new entrants seeking to leverage its internationally competitive regulatory environment. Among them was Vantage Tr

The year 2024 marked a period of rapid expansion for the GIFT City IFSC ecosystem, with several ambitious new entrants seeking to leverage its internationally competitive regulatory environment. Among them was Vantage Trade Finance IFSC Ltd ('Vantage'), a registered ITFS operator and finance company under the IFSCA framework, quietly building what its founders envisioned as a full-spectrum trade finance platform. Vantage had developed a sophisticated digital platform to facilitate invoice-based trade finance transactions for exporters and importers spanning multiple jurisdictions. Given the volume and cross-border sensitivity of transactions flowing through the platform, the integrity of its technology infrastructure was a regulatory obligation. Yet, by the close of the financial year ending March 31, 2026, the annual IT/IS audit, due within thirty days of year-end, had not been initiated. More troublingly, in February 2026, Vantage had quietly rolled out a significant upgrade to its core transaction-matching engine. No audit was commissioned before or after this upgrade. The concerns did not stop there. Vantage's disaster recovery site had gone untested for over eighteen months and the Business Continuity Plan remained frozen in time. Furthermore, transaction data was being archived in a proprietary format readable only through discontinued third-party software, raising questions about data retrievability. As part of its 2026 growth strategy, Vantage's Board explored diversifying into the issuance and management of 'Transition Bonds' to support 'hard-to-abate' sectors like steel and cement. However, during a strategy session, the Board noted a lack of enthusiasm from institutional investors. A preliminary market study commissioned by Vantage highlighted that while the potential for transition finance was high, the absence of a finalized Climate Finance Taxonomy in India and the lack of sector-specific decarbonization roadmaps were creating significant regulatory uncertainty and heightening risk perception among global funds. On the business expansion front, Vantage's Board approved the launch of two non-core activities, foreign exchange advisory and investment advisory services. Rather than establishing separately identifiable departments for each, both activities were folded into a single shared team with no firewalls or conflict-of-interest protocols. Mehta, the CFO, reassured the Board that a unified desk was perfectly reasonable for advisory functions. Meanwhile, a cluster of investor complaints had accumulated, with exporters alleging mis-selling of products. These complaints had been pending for over sixty days without acknowledgment. Compounding the problem, Vantage had never formulated a Board-approved grievance redressal or customer compensation policy. It was Ragini, the newly appointed Company Secretary, who first connected the dots. Her comprehensive compliance review note made one thing unmistakably clear, Vantage's growth ambitions had quietly outpaced its compliance foundations. Based on the above facts, answer the following questions: Examine the structural requirements for a finance company undertaking non-core activities, specifically regarding depatment separation and conflict-of-interest firewalls.