Legal & Compliance

Regulatory Information

Our regulatory status, compliance framework, AML obligations, and your rights under applicable UK and international regulation.

Effective: 01 January 2025
Regime: UK Regulatory Framework
Updated: 01 January 2025
Section 01

Company Registration

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Cairnfort Ltd
Registered in England & Wales
Incorporated under the Companies Act 2006. Registered Office: London, United Kingdom.
DetailInformation
Legal NameCairnfort Ltd
JurisdictionEngland & Wales
Registered OfficeLondon, United Kingdom
VAT StatusRegistered for VAT purposes in the United Kingdom
Business ActivityFraud Investigation and Asset Recovery Services (SIC: 74909)
Section 02

Regulatory Status

Cairnfort is a specialist fraud recovery and investigation company. It is important to understand our regulatory position clearly:

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Fraud Recovery Services

Our core investigative and recovery services β€” fund tracing, evidence preparation, and institutional liaison β€” are not regulated by the Financial Conduct Authority (FCA) as these do not constitute regulated financial activities as defined in FSMA 2000.

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Not a Financial Institution

Cairnfort is not a bank, payment service provider, or investment firm. We do not hold, manage, or invest client funds. We do not provide investment advice or financial product advice.

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Not a Law Firm

We are not regulated by the Solicitors Regulation Authority (SRA) and do not provide legal advice. Legal advice required in connection with your case must be sought from a separately regulated solicitor or barrister.

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AML Regulated

As a provider of services to clients relating to financial fraud, we maintain voluntary compliance with the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, applying AML and KYC procedures to all client engagements.

Important transparency notice: Fraud recovery companies in the United Kingdom are not currently required to be regulated by the FCA. We operate within the relevant legal framework and maintain voluntary compliance with applicable financial crime regulations. We encourage all clients to verify our legitimacy through the contact details provided on this page before engaging our services.

Section 03

Anti-Money Laundering Compliance

Cairnfort is committed to operating in full compliance with UK anti-money laundering legislation and maintaining the highest standards of financial integrity. Our AML framework includes:

  • πŸ”Ž
    Customer Due Diligence (CDD)We conduct standard and, where appropriate, enhanced due diligence on all clients before commencing services. This includes identity verification, source of funds enquiries, and risk assessment.
  • πŸ“Š
    Risk-Based ApproachWe apply a risk-based approach to client onboarding and ongoing monitoring, applying enhanced scrutiny to high-risk jurisdictions, Politically Exposed Persons (PEPs), and cases involving large sums or complex structures.
  • πŸ“‹
    Suspicious Activity ReportingWe have a designated Money Laundering Reporting Officer (MLRO) who is responsible for reviewing and, where required by law, submitting Suspicious Activity Reports (SARs) to the National Crime Agency (NCA).
  • πŸ“š
    Record KeepingWe maintain records of all CDD checks, transactions, and related correspondence for a minimum of five years as required by the Money Laundering Regulations 2017.
  • πŸŽ“
    Staff TrainingAll staff with client-facing or financial responsibilities receive regular AML training and are required to maintain awareness of current financial crime typologies and legislative requirements.
⚠️Providing false, misleading, or incomplete information during our KYC/CDD process may constitute a criminal offence under the Proceeds of Crime Act 2002 and the Fraud Act 2006. We are legally required to report suspected financial crimes to the NCA regardless of the impact on client relationships.
Section 04

Know Your Customer (KYC) Requirements

As part of our AML obligations, all clients must successfully complete our identity verification process before we commence any recovery work. This is a legal requirement, not an optional administrative step.

Verification LevelDocuments RequiredApplies To
Standard CDD Government-issued photo ID (passport or driving licence) and proof of address dated within 3 months All standard cases
Enhanced CDD Standard CDD documents plus source of funds declaration, bank statements, and additional supporting documentation High-value cases (over Β£50,000), high-risk jurisdictions, PEPs, complex cases
Corporate Verification Company registration documents, certificate of incorporation, director IDs, proof of registered address, and beneficial ownership declaration Corporate clients and business fraud cases

All documents are processed securely and retained in accordance with our Privacy Policy and the data retention requirements of the Money Laundering Regulations 2017. Documents are used solely for verification purposes and are not shared with third parties except as required by law.

βœ… We use secure, encrypted document submission through our client portal. We do not request verification documents by email, WhatsApp, or informal channels. If you are asked to submit identity documents outside the portal, contact us immediately.

Section 05

Data Protection Registration

Cairnfort processes personal data in the course of our services and is registered with the Information Commissioner's Office (ICO) as a Data Controller, as required by the Data Protection Act 2018 and UK GDPR.

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ICO Registration
Registered Data Controller with the Information Commissioner's Office. Our registration covers all processing activities related to client case management, identity verification, communications, and platform operations.

For full details of our data processing activities, legal bases, retention periods, and your rights, please refer to our Privacy Policy.

Section 06

Legal & Regulatory Framework

Our operations are conducted in compliance with, and subject to, the following principal legislation and regulatory frameworks:

Legislation / FrameworkApplication to Our Business
Proceeds of Crime Act 2002Money laundering obligations, SAR reporting duties, prohibited assistance offences
Money Laundering, Terrorist Financing & Transfer of Funds Regulations 2017Customer due diligence, enhanced due diligence, record keeping, staff training requirements
Fraud Act 2006Defines fraud offences relevant to cases we investigate; guides our evidence standards
Data Protection Act 2018 / UK GDPRAll personal data processing, client rights, data controller obligations
Computer Misuse Act 1990Boundaries of our investigative activities; compliance with lawful access standards
Financial Services & Markets Act 2000Defines regulated activities we do not perform; boundaries of our service scope
Consumer Rights Act 2015Consumer client rights regarding service quality, unfair terms, and redress
Electronic Communications Act 2000Electronic evidence standards and digital communications in investigations
Crime (International Co-operation) Act 2003Framework for international evidence sharing and law enforcement cooperation
UK Sanctions Regime (OFSI)Prohibition on dealing with sanctioned individuals or entities
Section 07

Relevant Regulatory & Reporting Bodies

The following regulatory bodies and agencies are relevant to our operations and to the fraud recovery process:

National Crime Agency (NCA)
The UK's lead agency against serious and organised crime. We submit Suspicious Activity Reports (SARs) to the NCA's Financial Intelligence Unit as legally required. Clients may also report fraud directly.
nationalcrimeagency.gov.uk β†’
Action Fraud
The UK's national reporting centre for fraud and cybercrime, operated by the City of London Police. We encourage all clients to submit a report to Action Fraud at the earliest opportunity and will assist with report preparation where required.
actionfraud.police.uk β†’
Financial Conduct Authority (FCA)
The FCA regulates financial services firms in the UK. While Cairnfort is not an FCA-regulated firm, the FCA maintains the Financial Services Register and ScamSmart resources to help consumers identify authorised firms and avoid scams.
register.fca.org.uk β†’
Information Commissioner's Office (ICO)
The UK's independent data protection regulator. You have the right to lodge a complaint with the ICO regarding our data processing practices at any time, without affecting your other legal rights.
ico.org.uk β†’
Office of Financial Sanctions Implementation (OFSI)
Part of HM Treasury, OFSI administers UK financial sanctions. We conduct sanctions screening on all clients against the UK Consolidated Sanctions List and international equivalents.
gov.uk/ofsi β†’
Section 08

Client Protections

As a client of Cairnfort, you benefit from the following protections under UK law and our internal policies:

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    Consumer Rights Act 2015Our services must be provided with reasonable care and skill, within a reasonable time, and at a reasonable price. You have statutory rights if we fail to meet these standards, including the right to require repeat performance or a price reduction.
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    Unfair Contract TermsWe do not include unfair terms in our contracts that would create significant imbalance in the parties' rights to your detriment. Any term that attempts to exclude rights you cannot lawfully waive shall be void.
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    Data Subject RightsYour rights under UK GDPR β€” including access, rectification, erasure, portability, and the right to object β€” apply in full. See our Privacy Policy for details on exercising these rights.
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    Access to CourtsNothing in our Terms restricts your right to bring a claim in the courts of England and Wales for breach of contract, negligence, or any other legal cause of action.
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    Whistleblower ProtectionsIf you have concerns about financial crime or regulatory misconduct in connection with your case, you are protected under the Public Interest Disclosure Act 1998 for making disclosures in good faith to appropriate regulatory authorities.
Section 09

Sanctions Compliance

Cairnfort maintains a zero-tolerance approach to financial sanctions compliance. We screen all clients, counterparties, and relevant third parties against applicable sanctions lists before and during any engagement.

We screen against the following sanctions regimes:

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    UK Office of Financial Sanctions Implementation (OFSI) β€” UK Consolidated Sanctions List
  • πŸ‡ΊπŸ‡Έ
    US Office of Foreign Assets Control (OFAC) β€” Specially Designated Nationals (SDN) List
  • πŸ‡ͺπŸ‡Ί
    European Union Consolidated Financial Sanctions List
  • 🌐
    United Nations Security Council Consolidated Sanctions List
⚠️We are legally prohibited from providing services to, or dealing with, sanctioned individuals or entities. Where a sanctions match is identified, we are required to freeze engagement, report to OFSI, and cease all services. This obligation overrides any commercial relationship and is not subject to client consent.
Section 10

Reporting & Disclosure Obligations

As an entity that assists in the recovery of criminally-derived funds, we operate within a framework of mandatory reporting obligations. Clients should be aware that we may be legally required to report certain information to authorities without prior notice to you:

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    Suspicious Activity Reports (SARs)Where we identify transactions or activities that give rise to knowledge or reasonable suspicion of money laundering or terrorist financing, we are required under the Proceeds of Crime Act 2002 to submit a SAR to the NCA's UKFIU. We may not be able to inform you of such a report.
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    Court Orders & Legal ProcessWe will comply with all valid court orders, production orders, and legal process requiring disclosure of client information. We will seek to notify you where legally permitted and where doing so does not prejudice a law enforcement investigation.
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    Tipping OffWe are legally prohibited from tipping off subjects of a SAR or live investigation. In certain circumstances, we may not be able to explain why case work has been suspended or why we cannot answer certain questions. This is a legal requirement, not evasion.
Section 11

Contact & Compliance Enquiries

For regulatory, compliance, or legal enquiries, please contact the appropriate department using the details below. We aim to acknowledge all compliance correspondence within 3 working days.

πŸ“¬ Compliance Contacts

Data Protectionprivacy@Cairnfort.com
Legal / Courtslegal@Cairnfort.com
ICO (Regulator)ico.org.uk Β· 0303 123 1113 β€” for data protection complaints
Action Fraudactionfraud.police.uk Β· 0300 123 2040 β€” to report fraud
FCA ScamSmartfca.org.uk/scamsmart β€” verify firm authorisation