Procedures Designed to Withstand Scrutiny
Banks, compliance departments and counterparties reviewing this firm will find our procedures documented here in plain terms.
Calibrated to the Transaction, Applied Without Exception
“Our procedures are designed to support responsible transaction administration and may include identity verification, beneficial ownership review, sanctions screening, source-of-funds inquiries and additional due diligence depending upon the nature, jurisdiction, value and risk profile of the transaction.”
The firm is a legal practice, not a bank or money services business, and we do not claim to be subject to regulatory regimes that do not apply to us. What we do claim - and document - is a disciplined, risk-based set of procedures appropriate to a firm that administers client funds under written escrow agreements in cross-border matters.
The Compliance Framework, Component by Component
Know Your Client - KYC
Government-issued identification and identity verification for individual parties, signatories and authorized representatives.
Know Your Business - KYB
Corporate registration documents, good standing evidence, articles, bylaws, officer and director verification for entity counterparties.
Beneficial Ownership
Identification of ultimate beneficial owners behind entity parties, consistent with the risk profile of the engagement.
OFAC Sanctions Screening
Screening of parties and beneficial owners against applicable sanctions lists before an engagement is accepted.
PEP Screening
Politically exposed persons screening where appropriate to the parties and jurisdictions involved.
Source of Funds
Source-of-funds inquiries where appropriate to the nature, value and risk profile of the transaction.
Transaction-Purpose Review
Review of the commercial rationale and documentation supporting the transaction's stated purpose.
Conflict Checks
Professional-responsibility conflict screening before any engagement is accepted or confidential information received.
AML Awareness
Anti-money-laundering awareness procedures calibrated to a legal practice, applied with professional judgment.
Secure Communications
Controlled channels for sensitive instructions and documents; verification protocols for any change of instruction.
Wire-Fraud Prevention
Standing verification protocols for payment instructions; no change of account details by unverified communication.
Document Retention
Organized retention of engagement records consistent with professional obligations and applicable law.
Confidentiality
Attorney-client confidentiality and careful handling of sensitive commercial information.
Cybersecurity Awareness
Practical controls around email authentication, document transmission and access to client information.
What Compliance Review May Mean for You
Compliance review occasionally requires us to ask uncomfortable questions, request additional documents, decline engagements, or decline to proceed with transactions whose purpose, parties or funding cannot be adequately verified. We regard that as the framework working as intended - and clients who share that view tend to be the clients we serve best.
Begin With a Confidential Consultation
Tell us about your transaction. We will explain how the framework applies to it.