Anti-Money Laundering Policy

1. Purpose and scope

Kevin Smith Legal is an SRA-regulated freelance solicitor practice. The practice is committed to preventing its services from being used for money laundering, terrorist financing, or the handling of criminal property. This policy applies to every enquiry, client, and matter, without exception. It exists to protect clients, the profession, and the integrity of genuine recovery work.

2. Client due diligence

Before any engagement is accepted, the practice will verify the identity of the client. Depending on the matter and the risk profile, this may include:

• Government-issued photographic identification and proof of address
• Evidence of ownership of the assets or accounts concerned
• Source of funds and source of wealth information where required by the regulations
• For executors and administrators, the grant of probate or letters of administration and evidence of authority

The practice cannot act where identity or ownership cannot be satisfactorily established, and it will not proceed on the basis of incomplete or inconsistent documentation.

3. Jurisdictional restrictions

The practice does not accept clients who are citizens or permanent residents of the United States, Germany, Italy, or France, because local licensing rules prevent it. Enquiries are screened for these jurisdictions at intake, both through self-declaration and the practice's own checks.

4. Source of funds and asset provenance

Crypto recovery work requires particular care with provenance. The practice assesses the documented history of the assets concerned, including purchase records, bank references, and on-chain evidence where available. Where forensic tracing is instructed through the practice's partner, BNG Software, its findings inform the practice's own risk assessment. The practice will not act to assert ownership over assets where the client's entitlement cannot be supported by evidence.

5. Payments and handling of funds

• The practice never requests or accepts payment upfront for case evaluations.
• Success fees, where agreed, are invoiced in pounds sterling and settled through regulated banking channels only.
• The practice does not accept payment in cryptocurrency, gift cards, or vouchers under any circumstances.
• Recovered funds are paid only to a bank account verified as belonging to the client. The practice does not take custody of client crypto assets.

6. Suspicious activity reporting

Where the practice knows or suspects that a person is engaged in money laundering or terrorist financing, it is required by law to make a report to the National Crime Agency and may be unable to tell the person that a report has been made. The practice will cease acting where required by law and will cooperate with lawful requests from the appropriate authorities.

7. Record keeping

Client due diligence records and matter records are retained for the periods required by the Money Laundering Regulations and professional obligations, and are handled in accordance with the practice's Privacy Policy.

8. Responsibility

Kevin Smith, as the sole practitioner, holds responsibility for compliance with this policy. The policy is reviewed annually and whenever legislation, regulatory guidance, or the nature of the practice's work requires it.