A Structured, Proportionate Approach
Finova operates within a defined compliance framework designed to ensure that all engagement is lawful, ethical, and aligned with applicable regulatory requirements across the jurisdictions in which we operate or engage.
The framework is risk-based and proportionate, reflecting the nature of Finova’s activities, the types of assets involved, and the jurisdictions and counterparties with whom we engage.
Compliance is not treated as a formality, but as a foundational condition of engagement.
Jurisdictional Alignment
Finova’s compliance framework is informed by, and aligned with, the requirements of multiple legal and regulatory regimes, including (where applicable):
- United Kingdom
- United States
- European Union
- United Arab Emirates
In addition, Finova recognises that specific engagements may trigger obligations under other national or supranational frameworks depending on asset type, counterparty location, origin, destination, or end use.
Engagement proceeds only where lawful alignment can be reasonably established.
Core Elements of the Framework
Finova’s compliance framework is structured around the following core elements:
Governance and Accountability
- Clear internal accountability for compliance matters
- Defined escalation and decision-making pathways
- Separation between commercial engagement and compliance oversight
Risk Assessment
- Initial and ongoing assessment of legal, regulatory, and reputational risk
- Consideration of jurisdiction, asset type, counterparty profile, and transaction structure
- Ability to decline or disengage where risk is not acceptable
Verification and Due Diligence
- Proportionate verification of counterparties and beneficial ownership
- Assessment of source of funds, source of assets, and lawful authority
- Ongoing review where engagement is sustained over time
Financial Crime and Sanctions Compliance
Finova’s framework incorporates controls and processes intended to mitigate exposure to:
- money laundering and related financial crime,
- proceeds of crime concerns, and
- sanctions and trade restriction breaches.
This includes alignment with:
- relevant AML and CTF principles, and
- applicable sanctions regimes administered by authorities in the UK, US, EU, and other jurisdictions.
Further detail is set out in:
- Financial Crime & Verification
- Sanctions & Jurisdictional Alignment
Information Handling and Confidentiality
Compliance extends beyond transaction execution to include:
- protection of confidential information,
- appropriate handling of personal and sensitive data, and
- secure communication practices.
Information is shared strictly on a need-to-know basis and retained only where lawful and appropriate.
(See: Information Security & Data Protection)
Partner and Counterparty Expectations
Where Finova works with partners or introduces counterparties, the compliance framework extends to:
- setting clear expectations regarding lawful conduct,
- requiring alignment with applicable sanctions and financial crime obligations, and
- reserving the right to disengage where standards are not met.
Finova does not compromise its compliance standards to facilitate engagement.
Refusal and Disengagement
An essential component of the framework is the ability to refuse to engage or to disengage where:
- legal or regulatory alignment cannot be established,
- required information is withheld or misrepresented, or
- risk exceeds acceptable thresholds.
Such decisions are taken deliberately and without obligation to proceed.
Continuous Review
Finova’s compliance framework is subject to:
- ongoing review,
- adaptation to regulatory developments, and
- refinement based on the nature of engagements undertaken.
This ensures that the framework remains appropriate, current, and effective.
Clarity First
Compliance is not a barrier to engagement — it is a prerequisite.
Where alignment exists, engagement proceeds with confidence.
Where it does not, clarity is provided early.