How we accept
a client.

Starting principle

We accept less work than comes to us. Declining a client whose activity we cannot frame, or whose purpose is unclear, is cheaper than the alternative — for us and for the institutions we work with.

Client identification (KYC)

Before any work begins, we identify the client. For individuals, we require a valid identity document and proof of address issued within the last three months. We check that documents are valid and consistent with each other.

Business identification (KYB)

For corporate clients, the set is broader:

• Current commercial registry certificate, or its access code;
• Beneficial ownership declaration, and a corporate structure diagram where there is more than one level;
• Identification and proof of address for directors and beneficial owners;
• Proof of the registered office address;
• A plain-language description of the activity: who the clients are, what they buy, how often, and where payments come from.

We verify the entity’s existence and registration status, and confirm that whoever signs has authority to bind the company.

Risk assessment

Every relationship is classified as low, medium or high risk, based on jurisdiction, sector, ownership structure, the nature of the relationship and the payment method. The classification determines how deep the due diligence goes and how often it is reviewed.

For high-risk relationships we apply enhanced due diligence: additional information on the source of funds and wealth, and express management approval before acceptance.

Sanctions and politically exposed persons

Before accepting a client, we screen the entity and its beneficial owners against applicable sanctions lists and identify politically exposed persons. A positive match does not mean automatic refusal — it means documented analysis and a decision at management level.

Record keeping and reporting

Identification documents and due diligence records are retained for the period required by law, counted from the end of the business relationship, under Portuguese Law 83/2017 and its implementing rules.

Where facts indicate money laundering or terrorist financing, we comply with our reporting duty to the competent authorities, without informing the client of that report.

Anti-bribery and conflicts of interest

We neither offer nor accept facilitation payments. Gifts and hospitality are subject to a limit and are recorded. Any conflict of interest, actual or apparent, is declared to the client before work starts — and if it cannot be managed, we decline the work.