Anti-Money Laundering & Financial Integrity Code

Charter on the Prevention of Illicit Financial, Asset, and Reputational Risk

I. Foundational Principle

Custos Fidei is governed by a doctrine of absolute financial and reputational integrity.
The prevention of money laundering, terrorist financing, sanctions circumvention, and illicit asset circulation is not regarded as a regulatory obligation alone, but as a core fiduciary duty inherent to the custodianship of intergenerational patrimony.

No mandate, relationship, or consideration—economic or otherwise—may override this duty.

II. Zero-Tolerance Policy

Custos Fidei applies a zero-tolerance approach to:

• money laundering and related predicate offenses,

• terrorist financing,

• sanctions evasion,

• corruption, bribery, and abuse of public office,

• trafficking in illicit or misappropriated assets,

• tax evasion or aggravated fiscal fraud,

• the circulation of stolen, looted, or unlawfully exported cultural property.

Any suspicion, inconsistency, or unresolved concern shall result in non-admission, suspension, or termination of the mandate.

III. Scope of Application

This Code applies to:

• all prospective and existing clients,

• all correspondents and introducers,

• all beneficial owners, controlling persons, and related parties,

• all assets, funds, artworks, and collections under advisory or custodial review,

• all jurisdictions involved directly or indirectly in a mandate.

No exemption applies by virtue of reputation, status, wealth, or referral source.

IV. Client Identification & Beneficial Ownership

Prior to acceptance of any mandate, Custos Fidei requires full and verifiable identification of:

• the client,

• all ultimate beneficial owners,

• controlling persons, trustees, protectors, or equivalent roles,

• legal entities, foundations, trusts, or special purpose vehicles involved.

Identification must be supported by reliable, independent, and contemporaneous documentation.

Opaque ownership structures, nominee arrangements, or unjustified complexity are treated as elevated risk indicators.

V. Source of Funds & Source of Assets

Custos Fidei requires a clear, lawful, and documented explanation of:

• the origin of funds, and

• the origin of assets (including artworks and collections).

This includes, where applicable:

• acquisition history,

• transactional records,

• inheritance or succession documentation,

• export, import, and customs compliance,

• prior valuation and insurance records.

Assets or funds whose origin cannot be clearly established, corroborated, and reconciled shall not be accepted.

VI. Enhanced Due Diligence (EDD)

Enhanced Due Diligence is mandatory in circumstances including, but not limited to:

• politically exposed persons (PEPs),

• clients or assets linked to high-risk jurisdictions,

• complex cross-border structures,

• significant cash-adjacent transactions,

• rapid movement or repeated re-structuring of assets,

• artworks with gaps in provenance or post-conflict history.

EDD may involve external legal, forensic, or compliance specialists operating under equivalent confidentiality and integrity standards.

VII. Sanctions, Watchlists & Restricted Jurisdictions

Custos Fidei conducts continuous screening against:

• international sanctions regimes,

• enforcement and regulatory watchlists,

• adverse media and reputational intelligence sources.

Mandates involving sanctioned individuals, entities, or jurisdictions are strictly prohibited.

Attempted circumvention or concealment of jurisdictional exposure constitutes grounds for immediate disengagement.

VIII. Continuous Monitoring & Review

AML obligations do not conclude upon mandate acceptance.

Custos Fidei applies ongoing monitoring, including:

• periodic review of client profiles,

• reassessment of risk classifications,

• scrutiny of changes in ownership, control, or jurisdiction,

• review of asset movement, restructuring, or disposition.

Any material change triggers renewed due diligence.

IX. Right of Refusal, Suspension, and Termination

Custos Fidei reserves the unconditional right to:

• refuse to enter into a mandate,

• suspend services pending clarification,

• terminate an engagement with immediate effect,

where AML, financial integrity, or reputational standards are not met.

No justification is owed, and no liability arises from such refusal or termination.

X. Confidentiality and Non-Disclosure of Controls

All AML reviews and findings are conducted under strict confidentiality.

Custos Fidei does not disclose:

• the methodology of its internal controls,

• the reasons for refusal or termination,

• or the existence of internal risk assessments.

This discretion is essential to preserve the effectiveness of the AML framework and the security of all parties.

XI. Mutual Protection Doctrine

This AML Code exists to protect both parties.

It safeguards:

• clients from legal, regulatory, and reputational exposure,

• Custos Fidei from institutional, civil, and criminal risk,

• entrusted patrimony from contamination by illicit origin or association.

Compliance is therefore a condition of access, not a negotiable requirement.

XII. Final Provision

Custos Fidei affirms that no asset, mandate, or relationship is worth compromising integrity.

Where certainty cannot be achieved, restraint shall prevail.
Where doubt persists, disengagement shall follow.

In preserving legality, transparency, and legitimacy, Custos Fidei preserves what endures beyond wealth:
trust, continuity, and institutional honor.