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Know Your Client (KYC) Charter

Principle

Custos Fidei accepts mandates exclusively on the basis of trust, integrity, and long-term alignment.
The establishment of such trust requires a thorough understanding of the parties involved, their provenance, and the context in which each mandate is undertaken.

Know Your Client procedures are therefore not treated as a regulatory formality, but as a foundational fiduciary obligation.

Scope of Application

This Charter applies to all clients, counterparties, intermediaries, correspondents, and associated parties engaged by Custos Fidei, without exception.

No mandate shall be initiated, continued, or renewed until the requirements set forth herein have been satisfied to the sole discretion of Custos Fidei.

Purpose of KYC

The objectives of Custos Fidei’s KYC framework are to:

  • Establish the identity, legal capacity, and beneficial ownership of the client

  • Assess the origin of assets and the legitimacy of their use

  • Ensure alignment with Custos Fidei’s ethical, reputational, and fiduciary standards

  • Prevent exposure to legal, regulatory, financial, or reputational risk

  • Preserve the integrity of collections, institutions, and individuals entrusted to our care

KYC serves to protect not only Custos Fidei, but also its clients, their collections, and all parties connected to a given mandate.

Risk-Based Approach

Custos Fidei applies a risk-based and proportionate approach to KYC.

The depth and scope of due diligence may vary according to, inter alia:

  • Jurisdiction of residence or operation

  • Nature and complexity of the mandate

  • Structure of ownership or control

  • Source and movement of assets

  • Exposure to politically, legally, or reputationally sensitive environments

Where circumstances so require, Enhanced Due Diligence (EDD) shall be conducted.

Information and Documentation

Clients may be required to provide, without limitation:

  • Valid identification and corporate documentation

  • Disclosure of ultimate beneficial owners

  • Information regarding source of wealth and source of funds

  • Relevant legal, tax, or succession structures

  • Any additional information deemed necessary to establish clarity and coherence

Failure or refusal to provide requested information may result in the declination or termination of the mandate.

Ongoing Monitoring

KYC is not a one-time exercise.

Custos Fidei reserves the right to:

  • Review and update client information periodically

  • Request supplementary documentation at any stage of the relationship

  • Reassess risk profiles in light of material changes

A mandate may be suspended or terminated should continued engagement no longer meet Custos Fidei’s fiduciary standards.

Right of Refusal

Custos Fidei retains the unconditional right to decline any mandate, without obligation to provide justification, where acceptance would compromise:

  • Professional integrity

  • Fiduciary independence

  • Reputational standing

  • Ethical alignment

The refusal of a mandate shall not give rise to any claim or liability.

Confidentiality

All information collected under this Charter is subject to strict professional secrecy and is handled in accordance with Custos Fidei’s Secrecy Charter and applicable laws.

Access to such information is limited strictly on a need-to-know basis.

Final Provision

KYC is not preparatory work.
It is the first act of custody.

Only when trust is established may discretion be exercised.
Only when clarity exists may silence be preserved.

On Engagement.

Inspired by Harpocrates, the ancient guardian of silence, Custos Fidei is governed by principles of discretion and restraint. Engagements arise, as a matter of preference, through confidential introduction via our network of trusted correspondents, including multi-family offices, private banking, trustees, and selected fiduciary advisors. On occasion, we are willing to consider direct approaches — though we reserve, without exception, the right to decline any engagement at our sole discretion and without explanation.

© 2026 by Custos Fidei 
Barcelona - Zürich 

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