Anti Money Laundering Policy

Version 1.0, effective 9 October 2026

1. About this policy

1.1This policy explains how Corven Law Ltd ("Corven", "we") guards against its services being used for money laundering, terrorist financing or a breach of financial sanctions. It applies to Corven and to everyone who works for it.

1.2Corven prepares written legal documents, reviews and answers at fixed published prices. We do not hold client money or run a client account. We do not act in the purchase or sale of property or businesses, form companies, provide registered office or nominee services, or act as a trustee, director or company secretary for anyone.

1.3We do not accept work that would make Corven an independent legal professional or a trust or company service provider under regulation 12 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. Where an instruction comes close to that line, such as paperwork for a transfer of shares, the Director reviews it before we accept it, and we decline it if it falls within regulation 12. For that reason we do not currently offer our company start pack, share paperwork, founders agreement, founder shareholders agreement or founder IP assignment.

1.4Even where those Regulations do not apply to us, we follow their approach as good practice. We remain bound by the Proceeds of Crime Act 2002, the Terrorism Act 2000 and the UK sanctions regime, which apply to everyone.

2. Who is responsible

2.1Our Director, Santosh Pandey, a solicitor of England and Wales, is responsible for this policy. He receives any internal report of suspicion and decides whether a disclosure is made to the National Crime Agency.

2.2We review this policy at least once a year, and sooner if the law or our services change.

3. Knowing our clients

3.1Before we start work we record the client's name and email address. For a business client we also record the company name and number and check the company on the Companies House register.

3.2Payment is taken in advance by card through Stripe. We do not accept cash.

3.3Where a client, or another party named in the instructions, is based outside the UK, or anything else gives us cause for concern, we check them against the UK Sanctions List before we start.

3.4We take extra care where instructions involve an unusual structure, money from an unexplained source, a party in a high risk country, or a client who is reluctant to give information. We ask further questions where needed, and we decline or stop the work if we are not satisfied.

4. Reporting suspicion

4.1Anyone working for Corven who knows or suspects that a client or anyone else is engaged in money laundering or terrorist financing must tell the Director straight away, and must not discuss it with the client.

4.2If we are asked to do anything that could amount to an offence under sections 327 to 329 of the Proceeds of Crime Act 2002, we will not go ahead unless an authorised disclosure has been made to the National Crime Agency under section 338 of that Act and the appropriate consent has been given.

4.3We will not tell a client or anyone else that a disclosure has been made, or is being considered, where that could prejudice an investigation.

5. Records

5.1We keep client details, instructions, the documents we deliver and payment records for at least five years after the work ends.

6. Training

6.1The Director keeps his knowledge of money laundering law and practice up to date. Anyone who later works for Corven will be trained on this policy before they start any client work.

7. Contact

7.1Questions about this policy can be sent to contact@corvenlaw.com.