AML & KYC Policy

Last Updated: 04/06/2026

1. Purpose

Revia Ltd is committed to maintaining appropriate systems, procedures and controls designed to identify, assess and mitigate the risk of financial crime, fraud, money laundering, terrorist financing, bribery, corruption and other unlawful activity.

This AML & KYC Policy outlines the measures adopted by Revia Ltd to support responsible business practices, protect clients and funding partners, and maintain appropriate standards of due diligence.

2. About Us

Revia Ltd

Company Number: 16503373

Registered Office:

Revia Ltd
Department Leeds Dock
Clarence Dock, 4 The Blvd
Leeds
LS10 1PZ

Website: www.revia.co.uk

Email: info@revia.co.uk

Telephone: 0113 4675024

Revia Ltd operates as a commercial finance, property finance and corporate finance advisory business.

3. Compliance Responsibility

Responsibility for maintaining this policy and associated procedures rests with:

Henry Pryce
Compliance & AML Officer
Revia Ltd

Responsibilities include:

• Maintaining appropriate AML and KYC procedures;
• Ensuring appropriate client and transaction risk assessments are undertaken;
• Ensuring appropriate sanctions and PEP screening procedures are maintained;
• Reviewing and escalating suspicious activity where appropriate;
• Ensuring relevant staff receive appropriate financial crime awareness and training.
• Reviewing financial crime risks;
• Supporting due diligence processes;
• Monitoring compliance controls;
• Reviewing higher-risk matters where appropriate;
• Maintaining records relating to compliance procedures.

4. Our Approach

Revia adopts a risk-based approach to financial crime prevention.

We are committed to:

• Acting with integrity and professionalism;
• Conducting reasonable due diligence;
• Verifying clients where appropriate;
• Maintaining appropriate records;
• Identifying potentially suspicious activity;
• Protecting our business, clients, lenders, investors and funding partners from financial crime risks.

5. Client Due Diligence (CDD)

Revia may undertake due diligence checks before or during the provision of services.

This may include requesting:

• Passport or driving licence;
• Proof of address;
• Company registration information;
• Director and shareholder information;
• Beneficial ownership and control information;
• Financial accounts;
• Bank statements;
• Existing lending information;
• Source of funds information;
• Source of wealth information;
• Business plans and supporting documentation.

Our due diligence may include identifying and verifying the client and, where applicable, its beneficial owners, and obtaining information regarding the purpose and intended nature of the business relationship or transaction.

We may also utilise electronic verification tools, compliance databases, publicly available information and third-party systems where appropriate.

6. Enhanced Due Diligence

Enhanced due diligence may be undertaken where higher-risk factors are identified, including:

• Politically Exposed Persons (PEPs);
• Sanctions concerns;
• Offshore entities;
• Complex ownership structures;
• Unusual transaction activity;
• Higher-risk jurisdictions;
• Transactions inconsistent with a client’s profile.
• Unusually large or complex transactions with no apparent economic or lawful purpose.

Where enhanced due diligence is required, Revia may obtain additional information regarding the client, beneficial owners, source of funds, source of wealth, purpose of the transaction and other relevant circumstances before deciding whether to proceed.

Additional documentation and verification may be requested where appropriate.

7. Ongoing Monitoring

Where appropriate, Revia may carry out ongoing monitoring throughout a client relationship.

This may include:

• Reviewing updated information;
• Requesting additional documentation;
• Reviewing changes in circumstances;
• Reassessing risk profiles.

8. Suspicious Activity

Where concerns arise regarding potential financial crime, fraud, sanctions, identity verification or unusual activity, Revia reserves the right to:

• Request additional information;
• Pause or delay applications;
• Decline to act;
• Terminate client relationships;
• Escalate concerns internally;
• Take any action considered reasonably necessary to protect the business and its stakeholders.
• Make a report to the appropriate authority where required by law.

Where suspicious activity is identified, the matter will be escalated to the Compliance & AML Officer for review. Where appropriate or legally required, a report may be made to the relevant authority. Revia will not disclose information where doing so would be unlawful or could prejudice an investigation.

Revia may refuse to proceed with any enquiry, application or transaction where concerns cannot be satisfactorily resolved.

9. Record Keeping

Revia maintains records relating to due diligence and compliance procedures where appropriate.

Records may be retained for up to six years following the conclusion of a client relationship, transaction or service engagement, or longer where reasonably required for legal, compliance, fraud prevention or dispute resolution purposes.

10. Data Protection

Personal and business information processed as part of due diligence procedures will be handled in accordance with applicable UK data protection legislation and our Privacy Policy.

11. Third-Party Providers

Revia may work with lenders, investors, funders, verification providers, compliance platforms, professional advisers and other third-party partners.

Relevant information may be shared where reasonably necessary to:

• Progress funding enquiries;
• Verify information;
• Conduct due diligence;
• Meet legal obligations;
• Facilitate transactions.

12. Limitation Of Services

Revia reserves the right to refuse, suspend or discontinue services where:

• Required documentation is not provided;
• Information supplied is inaccurate or misleading;
• Due diligence requirements are not satisfied;
• Financial crime concerns arise;
• Compliance concerns cannot be satisfactorily resolved.

13. Policy Review

This policy may be updated from time to time to reflect changes in legislation, business operations or industry best practice.

The latest version will always be available on our website.

14. Contact

For questions regarding this policy, please contact:

Revia Ltd

Email: info@revia.co.uk

Telephone: 0113 4675024

Department Leeds Dock
Clarence Dock, 4 The Blvd
Leeds
LS10 1PZ

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