Compliance Statement
We provide independent advisory services and we take compliance seriously. We operate under a written Compliance Program approved by our sole member. This statement summarises how we work. It is a general description, it is not legal advice, and it does not create obligations to any third party.
1. Who we are and what we do
We provide independent financial, corporate and tax-structuring analysis of transactions that our clients are already considering. We charge fixed project fees, stated in writing.
We are not a bank, a payment institution, an investment firm, a broker or an intermediary. We do not hold our clients’ funds or assets. We do not identify, introduce or source counterparties, we do not take part in negotiating or concluding our clients’ transactions, and we receive no payment or benefit from any counterparty. Our clients make their own decisions.
2. Our standards
We apply a compliance standard that goes beyond what the law requires of an advisory business. We do this by choice, to protect our clients, our banking and payment partners and ourselves. As a United States company we are also bound by United States sanctions law, which we follow at all times.
Our program follows the framework published by the US Office of Foreign Assets Control (OFAC): management commitment, risk assessment, internal controls, testing and auditing, and training.
3. Knowing our clients
Before we accept an engagement we:
- identify the client and, for a company, its owners and the people who control it;
- check sanctions lists and political-exposure status, using lawful and publicly accessible sources;
- understand the purpose of the engagement and where the funds used to pay us come from;
- assess the risk of the engagement and decide what further checks are needed.
We may ask for identity documents, company documents and supporting information. We keep this information up to date. If information is not provided, cannot be verified, or raises a concern we cannot resolve, we decline or end the engagement.
4. Payments
We accept payment only from our client, or from an entity under the client’s control that the client has disclosed to us, and only into accounts and wallets held in our own name. We verify the source and the sender of every payment, and we may reject, return or hold a payment that does not pass our checks. We do not accept cash or anonymous payments. Where a payment is made in digital assets, we apply additional controls, including verification of the sending address and screening of addresses and transactions.
5. Sanctions
We do not do business with sanctioned persons or in comprehensively sanctioned jurisdictions, and we do not help anyone to evade sanctions. If a check produces a possible match, we stop, review it and take legal advice before we proceed.
6. Integrity
- Anti-corruption. We do not offer, give, request or accept bribes or improper advantages, and we do not pass payments or benefits to public officials. Gifts and hospitality are kept modest and open.
- Conflicts of interest. We disclose conflicts to the client and manage them. If we cannot manage a conflict, we decline or withdraw from the engagement.
- Specialists and local advisers. When we use outside specialists we check them, bind them by written agreement and confidentiality, and pay them only for the work they perform. They do not introduce or approach counterparties.
7. Confidentiality, records and data
We keep client information confidential and use it only for the engagement and for compliance. We share it only with banks, payment and exchange providers, auditors and advisers who are bound by confidentiality, and with authorities when the law requires or permits.
We keep a register of our projects in two layers: a summary register that may be shown to banks and authorities, and detailed confidential records that are disclosed only where the law requires. We use secure channels for client information. We keep our compliance and transaction records for ten years.
8. Oversight
A Compliance Officer runs the program day to day. Our sole member approves the program at least once a year. An independent reviewer tests the program every year, and the people who handle clients and payments are trained every year. Incidents and concerns are recorded and reviewed.
9. Raising a concern
If you have a question, a complaint or a concern about our conduct, write to hello@grvgroup.us. We acknowledge every message within five business days and respond in substance within twenty business days. We do not tolerate retaliation against anyone who raises a concern in good faith.
10. Documents on request
Our formation documents and other corporate documents are available on request to banks and regulated counterparties, subject to confidentiality.
This statement may be updated from time to time. The version on this page is the current one.