Compliance & Ethical Conduct

Claves House accepts mandates that can be performed lawfully and responsibly. We do not arrange unlawful access, bribery, sanctions evasion, concealment of beneficial ownership, falsified records, tax evasion, unlawful surveillance, exploitative conduct or transactions involving illicit funds.

Before accepting or continuing a mandate, we may request information proportionate to its risk and applicable duties. This can include identity, authority, beneficial ownership, payer identity, transaction purpose and evidence of lawful source of funds or wealth. An introduction by a trusted institution does not automatically replace checks we ourselves must perform.

We assess applicable sanctions restrictions, including relevant ownership and control, before prohibited services or transactions proceed. Political exposure is assessed in context and is not treated as proof of misconduct.

Payment instructions identify the contracting party and approved recipient. Third-party payments require prior review and an appropriate lawful explanation. We do not accept anonymous payments, and we do not split transactions or alter descriptions to avoid verification, sanctions or reporting duties. A refund is made through a verified lawful route.

An exceptional route must still be a lawful route. We do not authorise facilitation payments or concealed benefits intended to secure improper influence. Relevant commercial conflicts and remuneration are disclosed and managed.

We may refuse or pause a request on reasonable legal, safety or compliance grounds and request clarification. Where reporting, freezing or restrictions are legally required, we comply. In some circumstances we cannot explain a report or disclose information that would compromise a lawful process.

Contact access@claveshouse.com about an apparent improper request or suspicious instruction. Do not send account credentials or unprotected sensitive documents. Nothing in our terms or confidentiality arrangements restricts a lawful protected disclosure or contacting a competent authority.