VADIVM.

Practice

Investor compliance and source of funds

This practice applies when a compliance question is used to delay or block payment, or when an investor needs an organised source-of-funds file before a claim can move forward. The paid first step is a document review: what exists, what is missing, and how the gap affects the underlying dispute. Details on how non-payment disputes typically unfold are set out in how non-payment disputes work in plain terms.

When this practice applies

A counterparty may cite incomplete KYC or an unresolved source-of-funds question as the reason a redemption or payment has stopped. Sometimes that objection is genuine. Sometimes it appears only after other grounds have failed. Either way, the investor needs a clear record of what was provided, what was requested, and when. This matters most where terms changed mid-relationship, as described in a composite scenario on stopped payments after terms change, or where the paying vehicle turned out to hold no assets, as in a composite scenario on non-payment where the vehicle held no assets. This work also supports the non-payment and redemption cases described under payment and redemption default work, where a compliance objection is the stated reason for refusal.

What the paid first assessment produces

The assessment is a paid piece of work, not a free consultation. It produces a written review of the documents already exchanged with the counterparty, a list of what is missing or disputed, and a note on whether the compliance objection is capable of justifying non-payment on its own terms. It does not produce a prediction of outcome. Where the objection looks unconnected to any real compliance concern, that is stated plainly, without projecting how a court or tribunal would treat it later.

How the work is scoped

Scope depends on the volume of records involved, the number of entities and accounts in the chain, and whether the counterparty's compliance process ran through more than one jurisdiction. A single redemption request with a thin paper trail is a different task from a multi-account structure with several intermediaries. Scope also depends on whether a third-party compliance report already exists and needs to be checked, or whether one has to be assembled from scratch. The assessment sets the scope before any further work is agreed.

Where this practice hands over

Once the compliance record is organised, the matter typically moves to whichever practice matches the underlying refusal, described under refusal by type. If the record is intended to support recognition or enforcement of a decision already obtained, it is handed to the enforcement work described under cross-border enforcement. This practice does not run in parallel with those tracks. It closes before they open, so the next step starts from a settled factual record rather than a disputed one.

What we do not take on

We do not act as a KYC or AML provider for banks, exchanges, or fund administrators, and we do not build ongoing compliance monitoring programmes. We do not certify that a client will pass a counterparty's internal compliance check, and we do not contact regulators or financial institutions on a client's behalf. There is no success fee arrangement on this work: payment is for the review performed, not for a result. The firm's registration can be checked in the public registry linked from this site, in line with the guidance under how to verify a law firm. Broader service scope sits under services.

Omar Halabi