Legal
We carry out appropriate client due diligence before an engagement, in line with applicable obligations. We do not act where we cannot satisfy ourselves as to the source of instructions or funds.
Because the work concerns a person's records and assets, we establish who we are acting for before we begin. Verification protects the client as much as us: it makes certain that an account of someone's exposure is only ever produced for that person, or for someone they have properly authorised to receive it.
We confirm identity and, where relevant, the authority of the person instructing us, the source of those instructions, and the position against sanctions lists and politically exposed person criteria. For a written account or a standing report we ask for a government document and a second piece of evidence. Unnamed monitoring, which never produces a report about a named person, does not require this.
We cannot act for anyone subject to international sanctions, or who is the subject of an active arrest warrant, including an Interpol notice. We decline any instruction whose purpose is to evade sanctions, tax or another legal obligation, and we will end an engagement if that becomes its purpose.
These checks reflect the obligations that apply to work of this kind in the United Kingdom, together with our own standards, which in places are stricter. They are a condition of engagement rather than an optional step, and they are the same for everyone.
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