Compliance and Law Enforcement Requests Policy

1. Purpose and scope

1.1 This Compliance and Law Enforcement Requests Policy (the Policy) describes the principles the Firm applies to two related subjects: (a) the compliance checks the Firm must carry out before and during an engagement; and (b) the way the Firm handles requests for information or action from law enforcement, regulators, courts, and other third parties.

1.2 This Policy is a general statement of approach. It is not legal advice, does not create rights for any third party, and does not limit what the Firm must do to comply with a binding legal obligation.

1.3 Terms used but not defined here have the meaning given in the Website Terms of Use and the Privacy Policy.

2. Definitions

• Authority means a court, law enforcement agency, regulator, tax authority, or other public body with power to compel the production of information or to require action.
• Request means any demand, order, subpoena, warrant, notice, or informal ask for information, documents, or action, whether from an Authority or a private third party.
• Client due diligence (or CDD) means the measures the Firm takes to identify and verify a client and any beneficial owner, to understand the nature of the matter, and to assess risk.
• Privileged information means information protected by legal professional privilege, legal advice privilege, litigation privilege, or an equivalent professional secrecy protection under Applicable Law.
• Reporting obligation means a legal duty on the Firm to report information to an Authority, such as a suspicious activity report, where Applicable Law imposes one.

3. Our compliance commitments

3.1 The Firm is committed to:

1. complying with the anti-money-laundering, counter-terrorist-financing, sanctions, anti-bribery, and tax-transparency laws that apply to it;
2. maintaining proportionate systems and controls to identify and manage financial-crime risk;
3. protecting client confidentiality and privilege, and disclosing client information only where permitted or required by law and by professional rules;
4. dealing with Authorities professionally and cooperatively within the limits set by law and professional obligations; and
5. keeping this Policy under review as the law and the Firm’s practice develop.

3.2 The specific regimes that apply to the Firm are identified at Owner to list applicable AML, sanctions, export-control, anti-bribery, and reporting regimes.

4. Client identification and verification

4.1 Before the Firm accepts an engagement, and in some cases before it can discuss a matter in detail, it may be required to identify and verify the client and, where the client is an entity, its beneficial owners and the individuals authorised to instruct the Firm.

4.2 The Firm may ask for documents and information such as identification documents, evidence of address, corporate records, ownership structures, and details of the purpose and intended nature of the matter. The exact requirements depend on the client type and the risk assessment.

4.3 The Firm may use third-party verification tools or services for these checks. Any such provider acts under contract and is subject to the Privacy Policy. Owner to confirm whether such tools are used and to name the providers.

4.4 If the Firm cannot complete the checks it is required to carry out, it cannot act, and may be prevented by law from explaining the reason in full.

5. Anti-money-laundering and counter-terrorist financing

5.1 The Firm does not act, and will not knowingly assist any person, in laundering the proceeds of crime, in financing terrorism, or in arrangements designed to disguise the origin, ownership, or control of funds or assets.

5.2 Where Applicable Law requires it, the Firm applies a risk-based approach, carrying out standard, simplified, or enhanced due diligence according to the risk presented by the client, the matter, the jurisdictions involved, and the delivery channel.

5.3 The Firm keeps the matter under review and will reassess risk if circumstances change, including if instructions change in a way that does not make commercial or legal sense.

6. Sanctions and export controls

6.1 The Firm is subject to economic-sanctions laws that prohibit dealing with certain persons, entities, and jurisdictions, and may be subject to export-control laws that restrict the provision of certain services or technical assistance.

6.2 The Firm screens clients and relevant connected parties against applicable sanctions lists before acting and, where appropriate, during a matter. Owner to confirm the screening approach and lists used.

6.3 The Firm will not provide services that would breach sanctions or export controls, and may be required to freeze dealings, decline to act, or make a report if a sanctions issue arises. Where a licence or authorisation is available and appropriate, the Firm may apply for one.

7. Source of funds and source of wealth

7.1 Where required by Applicable Law or by the Firm’s risk assessment, the Firm will seek to understand the source of the funds used in a matter and, in higher-risk cases, the client’s overall source of wealth.

7.2 The Firm may ask for supporting evidence and may decline to receive funds, or return them, if their origin cannot be satisfactorily explained.

7.3 The Firm’s handling of client funds is also subject to the Fees, Cancellations and Refund Policy and to the client-account rules that apply to it.

8. Politically exposed persons and high-risk factors

8.1 Where a client, a beneficial owner, or a close associate is a politically exposed person, or where other high-risk factors are present, the Firm applies enhanced due diligence and may require senior approval before acting.

8.2 Enhanced measures may include additional identity and background checks, closer examination of the purpose of the matter, more detailed source-of-funds enquiries, and more frequent review.

9. Ongoing monitoring and record-keeping

9.1 The Firm monitors matters on a risk-sensitive basis to check that the work remains consistent with what it knows about the client and the matter.

9.2 The Firm keeps records of the checks it carries out, the information it obtains, and the decisions it makes, for the period required by Applicable Law and professional rules. Owner to insert the applicable record-keeping period. Retention is also addressed in the Privacy Policy.

10. Mandatory reporting and restrictions on disclosure

10.1 In some jurisdictions the Firm has a legal duty, in defined circumstances, to report knowledge or suspicion of money laundering, terrorist financing, or certain other matters to a designated Authority. Where such a duty applies and is engaged, the Firm must comply with it.

10.2 The law may also prohibit the Firm from telling the client or a third party that a report has been made or is being considered (often called “tipping off”). Where that prohibition applies, the Firm cannot explain a delay or a decision that results from it.

10.3 Reporting obligations and privilege interact in a way that is technical and jurisdiction-specific. The Firm takes advice where necessary to ensure that it both meets any mandatory reporting obligation and preserves privileged and legally protected information that is not reportable. Owner to confirm the applicable reporting regime, the designated Authority, and the privilege exemptions.

11. Declining, pausing, or ending work on compliance grounds

11.1 The Firm may decline to take on a matter, or may pause or stop work on an existing matter, where required or permitted by Applicable Law or professional rules for compliance reasons, including an unresolved due-diligence gap, a sanctions concern, or a suspicion that triggers a reporting obligation.

11.2 Where the Firm stops acting, it will do so in a manner consistent with its professional obligations, as described in section 17 of the Website Terms of Use, and will take the steps it is permitted to take to limit prejudice to the client. Some steps or explanations may be restricted by law.

12. Requests from authorities: general approach

12.1 The Firm treats every Request seriously and handles it through a defined internal process rather than on an ad hoc basis.

12.2 The Firm’s guiding principles when it receives a Request are: verify the source and authority; understand the legal basis; assess privilege and confidentiality; disclose only what is legally required; keep a record; and, where permitted, tell the affected client.

12.3 The Firm does not volunteer client information to an Authority in the absence of a legal obligation or a recognised lawful basis, and does not treat cooperation as a reason to exceed what the law requires.

13. Verifying the authority and the legal basis

13.1 On receiving a Request, the Firm seeks to confirm: (a) the identity of the person or body making it; (b) that they have legal power to make it; (c) the specific legal provision or form of process relied on; (d) the jurisdiction whose law is said to apply; and (e) any deadline and its basis.

13.2 The Firm may ask for the Request to be put in writing on official letterhead, for a copy of any court order or warrant, and for the contact details of a responsible official.

13.3 If a Request appears to lack a proper legal basis, is addressed to the wrong entity, or does not follow the required procedure, the Firm may decline to act on it until the defect is corrected, unless doing so would itself breach the law.

14. Reviewing and narrowing scope

14.1 The Firm reviews the scope of each Request against the stated legal basis. Where a Request is broader than the basis justifies, the Firm may seek to narrow it, for example by limiting the date range, the custodians, the categories of document, or the individuals concerned.

14.2 The Firm aims to provide what is legally required and no more, and to avoid disclosing information about persons who are not the subject of the Request.

15. Privilege and professional secrecy

15.1 Legal professional privilege and equivalent professional secrecy protections belong to the client, not the Firm, and the Firm will assert them on the client’s behalf where they apply.

15.2 Before responding to a Request, the Firm reviews the material for privileged and legally protected content. The Firm will not disclose privileged information unless privilege has been validly waived by the client, or a court or other competent body with jurisdiction has ordered disclosure after the privilege claim has been properly considered, or Applicable Law otherwise clearly requires it.

15.3 Where a Request would require disclosure of privileged material, the Firm will, where possible, notify the client so that the client can take steps to protect the privilege, including seeking to challenge the Request.

15.4 Nothing in this Policy authorises the Firm to breach a duty of confidentiality or privilege that Applicable Law and professional rules require it to maintain.

16. Data minimisation and how we respond

16.1 When the Firm does disclose information in response to a Request, it discloses only the information that is within the lawful scope of the Request and that is not protected from disclosure.

16.2 Where practicable, the Firm redacts information that is outside scope, that identifies unrelated third parties, or that is privileged, and it records what was disclosed, to whom, and on what basis.

16.3 The Firm provides information in a proportionate format and does not give direct system access to an Authority unless lawfully compelled to do so.

17. Notice to affected clients

17.1 The Firm’s general position is to tell a client when the Firm receives a Request for that client’s information, so that the client can seek advice and, if appropriate, object.

17.2 The Firm will not give notice where it is legally prohibited from doing so, where a court has ordered that notice be withheld, or where the Firm reasonably believes that notice would create a risk to life, safety, or the integrity of an investigation and the law permits notice to be delayed. Where notice is delayed, the Firm will give it once the restriction ends, if it is still relevant and lawful to do so.

18. Confidentiality of the request

18.1 The Firm treats the existence and content of a Request as confidential and limits knowledge of it to those who need to be involved in handling it.

18.2 The Firm keeps Requests and its responses in a secure record, subject to the retention approach in the Privacy Policy.

19. Emergency and preservation requests

19.1 Where an Authority asserts that there is an emergency involving a risk of death or serious harm, the Firm will assess the Request urgently and may act on a shorter timeline, while still seeking to confirm authority and legal basis and to protect privileged information.

19.2 The Firm may agree to preserve specified information for a reasonable period pending a formal legal process, without disclosing the information, where that is lawful and proportionate.

20. Challenging requests

20.1 The Firm may challenge a Request, or support a client in challenging it, where the Request is unlawful, overbroad, improperly issued, or seeks privileged or protected information, and where a challenge is available under Applicable Law.

20.2 A decision to comply, to narrow, or to challenge is taken with advice where needed and is recorded with reasons.

21. Individual and data-subject requests

21.1 Requests from individuals to exercise data protection rights are handled under the Privacy Policy, section 16, and are subject to the same protections for privilege and client confidentiality described in this Policy.

21.2 A request framed as a data protection request will not be used to obtain another person’s privileged or confidential information, or information the Firm is required to withhold.

22. Governance, training, and the responsible contact

22.1 Responsibility for compliance matters and for handling Requests sits with Owner to insert the role responsible, for example the compliance principal or money-laundering reporting officer.

22.2 The Firm provides its personnel with appropriate guidance and training on financial-crime risk, confidentiality, privilege, and the process in this Policy. Owner to confirm the training arrangements.

22.3 The Firm reviews this Policy and its underlying procedures periodically and after any significant incident or change in the law.

23. Raising concerns and whistleblowing

23.1 Anyone within the Firm who has a concern about financial crime, a Request, or compliance with this Policy is expected to raise it with the responsible contact in section 22, and may do so confidentially.

23.2 The Firm will not penalise a person for raising a genuine concern in good faith. Applicable Law may provide additional protection for protected disclosures. Owner to insert any external reporting channel required or available.

24. Complaints and non-waivable rights

24.1 If you consider that the Firm has mishandled a Request or a compliance matter that affects you, you may complain using the details in section 26.

24.2 Nothing in this Policy removes any right you have that cannot be waived under Applicable Law, including the right to seek a remedy from a court or competent Authority, the right to complain to a supervisory authority about the handling of personal information, and any protected rights of a client in respect of privilege and confidentiality.

25. Changes to this policy

25.1 The Firm may update this Policy from time to time. The current version is the one published on the website, with the effective date shown at the top.

26. How to contact us

26.1 Requests from Authorities and questions about this Policy should be directed to the Firm at inquiries@ioannadigital.example (Owner to confirm the monitored contact address, and consider a dedicated legal-requests address and postal address for service).

26.2 Sending a Request to any other address may delay the Firm’s response. The Firm does not accept service of legal process by a method not permitted by Applicable Law.