AML and sanctions statement, 2 November 2026

Anti-money laundering and sanctions

Justice Alliance Party Limited is not a bank and it does not hold client money. This statement explains the checks that follow from international anti-money-laundering standards, including the FATF Recommendations, and from the duties that apply to a Hong Kong company when it deals with people, payments, and professional partners.

The same check is not automatic for every partner and every matter. A law firm, a forensic firm, and this company can have different duties. What follows is the standard this company applies to its own work.

What the company will do

• Identify the client before a matter proceeds beyond an initial inquiry, and identify a beneficial owner where the client is not a natural person acting for themselves.
• Screen the names it is given against sanctions and related restrictions that apply to the company.
• Ask, when a compensation step is reached, about the source of funds and the account or wallet that is to receive them. The destination is an account or a wallet the client controls. The company does not receive the recovered cryptocurrency as owner or as holder.
• Keep the records of those checks with the matter, for as long as the matter record is kept. See the Privacy Policy.
• Refuse, pause, or end a matter if the check cannot be completed, if the person is outside the clients the company accepts, or if the company suspects that the service would conceal proceeds of crime or breach sanctions.
• Report to a competent authority where the law requires a report. The company does not tell the subject that a report has been made where the law forbids that disclosure.

What the company will not do

• It will not accept an engagement whose purpose is to hide the origin of funds, to evade sanctions, or to move value for a third party who will not be identified.
• It will not take custody of cryptocurrency or fiat in order to "clean" it, route it, or hold it.
• It will not ask for a seed phrase or remote access as part of a check. Identity documents are not the same thing as secrets that spend the coins.

Clients the company does not accept

Due to international regulatory requirements, Cirius Justice does not accept clients who are citizens or permanent residents of the United States, Germany, Italy, or France.

Questions about this statement: claims@ciriusjustice.com. Updated 2 November 2026.