Due Diligence

Investigative due diligence services

Aperio Intelligence provides non-financial due diligence investigations, focusing on the track record, reputation, associations and likely integrity of one or more subjects. This type of investigative due diligence – depending on circumstances also referred to as “integrity due diligence”, “ethical due diligence” or “enhanced due diligence” – is critical to understanding the bona fides of a third party.

We go beyond traditional financial or legal due diligence methods which do not typically address human behavioural issues, and may be undermined by deliberate misrepresentation, or opacity.

Aperio’s due diligence team has substantial experience gathering and analysing information from across the world, helping you make sense of even the most complex and challenging scenarios.

For further information on how Aperio can support you, please contact Gunita Thethy, Head of Due Diligence: gunita.thethy@aperio-intelligence.com

Our work includes examples such as:

Determining the veracity of statements made by Ultra-High Net Worth individuals concerning their source of wealth
Understanding the ultimate beneficial ownership and control of a group of companies involving multiple complex offshore legal structures
Providing succinct analysis of the evolution and current status of complex litigation proceedings across multiple jurisdictions
Identifying direct and indirect exposure to politically exposed individuals, and the nature and possible consequences of those relationships
Assessing the conduct and reputation of senior management teams and/or senior individuals, highlighting matters that may be hidden or unclear
Providing additional contextual intelligence to support investigations into alleged fraud or misconduct
Contributing additional insight into financial crime-related concerns, including tax evasion, breaches of sanctions legislation, terrorist financing or bribery and corruption allegations
Investigating concerns relating to human rights abuses or environmental crime

We are thought leaders on financial crime issues, publishing our monthly Financial Crime Digest which summarises key technical developments & matters of interest to anti-financial crime professionals.

Financial services
Professional services
Corporates
Family offices and individuals
Charities, education and sport

Financial services

We undertake enhanced due diligence of varying intensity, based on the risk profile of the subject and the client's requirements, on behalf of regulated financial institutions, including investment and corporate banks, private banks, asset managers, hedge funds, private equity houses, insurers and reinsurance firms.

The financial services industry is highly regulated, given it is particularly exposed to customer-related risks of money laundering, tax or sanctions evasion, bribery and corruption, market manipulation and insider trading.

Full compliance with regulations is therefore critical to business success, quite apart from the risks to a company’s reputation through association with inappropriate parties. We conduct effective and timely examinations of subjects to identify and assess possible financial crime or reputational risks.
Examples of this work include
- Assessing the sources of wealth of Ultra High Net Worth / High Net Worth individuals.
- Determining the beneficial ownership and control of legal entities.
- Considering the provenance and accuracy of allegations made against a subject.
- Identifying and assessing the presence and political affiliations of politically exposed persons.
- Addressing the potential for sanctions and tax evasion risks.
- Reviewing the significance of contextual factors, including geopolitical risks.
Professional services

We support professionals, such as lawyers, accountants, real estate specialists, and trust and corporate service providers to assess financial and reputation risks linked to their prospective or actual clients, or in conjunction with them on behalf of their clients.

Sectors such as these, outside of the financial services industry, are attracting increasing regulatory attention given concerns they could be used unwittingly as conduits for money laundering and other forms of financial crime. We assist our clients to safeguard their position and reputation by carrying out due diligence to complement their internal capacity and capabilities.
Examples of this work include
- Assisting accountancy firms to vet prospective clients with higher risk profiles.
- Working closely with law firms to help advise their clients on matters such as sanctions risks.
- Supporting trust and corporate service providers to determine legitimacy of client funds.
- Screening parties to commercial real estate transactions to identify possible money laundering risks.
Corporates

We undertake investigative due diligence for corporate clients, in particular those seeking to do business internationally or in unfamiliar markets. Our clients include a range of publicly-listed companies and those covered by legislation concerning issues such as anti-bribery and corruption, conflict minerals, human rights or modern slavery.

Our work for corporate clients includes support for their legal and compliance teams to address potential compliance risks. We also support transaction teams seeking to obtain greater insight into specific subjects, industries or economies.

Our team is very familiar with relevant legislation such as the US Foreign Corrupt Practices Act, the UK Bribery Act and the French Sapin II law.
Examples of this work include
- Investigating the track record of potential joint venture or other business partners
- Understanding how an organisation wins or retains business
- Confirming the ownership or control structure of legal entities to screen for sanctions risks
- Mapping corporate associations, affiliations or political ties
- Considering reputation risks arising from the way an organisation conducts business
- Reviewing the reputation and background of key suppliers
- Identifying and assessing risks such as labour disputes or violations
Family offices and individuals

We conduct investigative due diligence for private individuals, and for single or multi-family offices. Such work may focus on compliance risks, such as mitigation of financial crime threats, or may be driven by a desire to identify more information to make business decisions in relation to an investment opportunity, competitor, target or proposed association.

High profile and high net worth families and individuals often come under sustained pressure to make political and business associations, for opportunistic business, political or societal motivation. A poor choice of association or alliance, while being above board legally, can burden a reputation for decades after the event - in the media, in business and political circles, and in society at large, exacerbated by the near-permanence of the online record. This can include being passed over for prestigious national positions, senior non-executive appointments, and high-profile roles in the charitable sector. We regularly conduct extensive background checks on behalf of high profile and high net worth family offices and individuals into the integrity of individuals and entities who seek to be associated with them.

Similarly, high net worth individuals may be involved in philanthropic activities, motivated by a desire to give back to society and support worthwhile causes. We help clients assess the reputation of potential donors to their causes, and of the potential beneficiaries of their philanthropy, to ensure their behaviour is consistent with our clients' existing perception of them.
Charities, education and sport

We undertake work for a variety of charitable, educational and sporting establishments. These enquiries typically focus on integrity and reputational concerns, given the importance of these matters to our clients.
Examples of this work include
- Investigating agents, brokers or introducers, to better understand their backgrounds and any integrity risks
- Reviewing key donors, to understand the legitimacy and integrity of funds introduced and their general reputation
- Assessing prospective business partners, such as overseas partners for educational establishments, to ensure they operate legally and ethically

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07/11/2024

Financial Crime Digest Octob...

Financial Crime Digest

This issue includes:

Special feature: Financial sector in West Africa challenged by rising cyber threats.
TD Bank fined in historic US enforcement action for massive AML failings
First FATF Week under new Mexican Presidency concludes
French judges give green light to terrorism financing trial against Lafarge
UK publishes draft crypto-asset reporting regulations under OECD framework
UK Sanctions spotlight: Developments and measures adopted in October
US Sanctions spotlight: Developments and measures adopted in October
EU Sanctions spotlight: Developments and measures adopted in October
Aperio analysis: Pavel Durov’s fall from French favour
Environmental, Social and Governance updates

View issue