Client Acceptance Policy

Last updated: November 2026

Whom we act for

We act for founders, operators, investors and companies in technology, finance, gaming and related industries, and for private clients with cross-border affairs. We take a matter when it falls within our practices, we have the capacity to do it properly, due diligence under our KYC / AML Compliance Statement can be completed, and the purpose of the engagement is lawful in every jurisdiction it touches.

What we decline

• Matters whose purpose is to conceal ownership, evade tax, avoid sanctions or launder the proceeds of crime.
• Clients who will not provide identification, ownership or source-of-funds information, or who provide information we cannot verify.
• Businesses whose activity is illegal where it is carried on, including unlicensed gambling aimed at markets that require a licence, unlicensed financial services, and the sale of products prohibited in the target market.
• Matters where the client’s instructions would require us to mislead a regulator, bank, court or counterparty.

Prohibited jurisdictions

We do not act for persons or entities resident, registered or beneficially owned in, or for transactions connected with, the following jurisdictions: the Russian Federation, the Republic of Belarus, the Democratic People’s Republic of Korea, the Islamic Republic of Iran, the Syrian Arab Republic, Cuba, and the temporarily occupied territories of Ukraine. This list follows the sanctions regimes of Ukraine, the EU, the UK and the US and is applied without exception.

Restricted jurisdictions

For jurisdictions on the FATF list of jurisdictions under increased monitoring or the EU list of high-risk third countries, and for others we assess as high-risk, we act only after enhanced due diligence and approval by the firm’s principal. The lists change; we apply the version current at the time of acceptance and at each periodic review.

High-risk industries

Gambling, crypto-assets, payment services, affiliate marketing, nutra and adult are industries we know well and serve, subject to enhanced due diligence. We require that the activity be licensed or lawfully unlicensed where it operates, that advertising and product comply with the rules of the target markets, and that the payment flows be transparent.

Conflicts of interest

Before accepting a matter we check whether we act, or have acted, for another party whose interests conflict with yours. We do not act for both sides of a transaction or a dispute. Where a conflict arises during a matter, we tell the affected clients, stop work on the conflicting part, and continue only where the clients give informed consent and it is possible to protect both. Information received from one client is never used for another.

Politically exposed persons

We act for politically exposed persons and their close associates only after enhanced due diligence on source of wealth and with approval by the firm’s principal.

Ending a relationship

We may decline a new matter or end an existing engagement where the criteria in this policy are no longer met. Where the law allows, we explain why; where it does not, we do not.

This document is provided as general information and may be updated from time to time.