Client due diligence policy

When we run the checks

Before the engagement letter and before the first payment. We do not start an incorporation, file a bank application or take a deposit until due diligence is complete. It does not stop there: we refresh the file when the structure, the shareholders or the nature of the business changes, and in any case at least once a year.

What we ask from individuals

From every director, shareholder and beneficial owner holding 25% or more:

• a valid passport, plus a short video call holding the document when the check is remote;
• proof of residential address no older than three months: a utility bill, a bank statement or a similar document;
• a short description of the business: what you do, who you trade with, where the money comes from and where it goes;
• the source of funds for the company set-up and, in complex cases, the source of wealth more broadly.

What we ask from companies

• the certificate of incorporation and the constitutional documents;
• the registers of directors and shareholders and an ownership chart down to the ultimate beneficial owners;
• individual documents for every beneficial owner holding 25% or more, as listed above;
• where needed, the latest financial statements or a bank statement showing real activity.

How we check

• we screen every party against the UN, Hong Kong, UAE, US, EU and UK sanctions lists;
• we check for politically exposed persons and for adverse mentions in open sources;
• we test whether the business description, the countries of the counterparties and the expected volumes fit together;
• for politically exposed persons, complex structures and FATF-listed jurisdictions we apply enhanced due diligence: more documents, more questions, and a senior partner takes the decision.

Who we do not work with

• sanctioned persons and companies, and structures built to evade sanctions or export controls;
• anyone unwilling to disclose the ultimate beneficial owners, or proposing nominee ownership without disclosure;
• businesses whose source of funds cannot be supported with documents;
• unlicensed financial, payment, crypto and gambling services, and goods or services that are illegal in the client country or in the jurisdiction of the company;
• companies that want a shell with no real activity and no intention to file.

We may decline an engagement or stop work at any stage. We do not always give the reason: in some cases the law does not allow us to.

How we keep your data

Documents are kept in secure storage accessible only to the people working on your matter. We share them only with banks, payment platforms, auditors and registries as part of your engagement, and on a lawful request from a regulator. We do not sell data or use it for marketing. Records are kept for at least five years after the relationship ends, as Hong Kong and UAE law require, and are then destroyed.