The framework behind every Realivo mandate.
Registration, anti-money-laundering practice, KYC, data protection, and conduct standards — set out in the same detail we apply to the mandates themselves.
Realivo Group Ltd
Companies House № 16712204 · Public register at find-and-update.company-information.service.gov.uk
London E13 8EE, UK
347 Barking Road · UK statutory address on file
EU 5MLD & UK MLR 2017
Written policy, updated annually
UK & EU GDPR
Regulation 2016/679 · DPA in force with all processors
Registration and corporate accountability
Realivo Group Ltd is a private limited company incorporated in England and Wales under the Companies Act 2006, registered with Companies House under number 16712204. The registered office is 347 Barking Road, London E13 8EE. All corporate filings — annual confirmation statement, statutory accounts, persons with significant control (PSC) register, and director appointments — are maintained on the public Companies House register and updated within the statutory windows.
Director accountability sits at the level of the appointed director(s) of record. Statutory duties under sections 171 to 177 of the Companies Act 2006 (duty to act within powers, promote the success of the company, exercise independent judgement, exercise reasonable care, avoid conflicts, and declare interests) inform how mandates, counterparties, and internal decisions are documented.
- Companies House filings (CS01, AA accounts, PSC01–PSC09 as applicable) submitted within statutory deadlines
- Director register, PSC register, and register of members maintained at the registered office
- Corporate resolutions for material mandates recorded in writing
- UTR held with HMRC; UK corporation tax returns filed on schedule
- Separate operating offices (London HQ, Frankfurt DACH, Valencia Southern Europe) coordinated under a single UK parent
- Independent verification available at any time via the free public Companies House search
Every Realivo mandate is executed by a named UK-registered legal entity of public record. Counterparties can confirm existence, standing, and director details without contacting us.
Anti–money laundering framework (5MLD and MLR 2017)
Realivo operates an AML framework aligned with the EU Fifth Anti-Money Laundering Directive (Directive (EU) 2018/843, "5MLD") and the UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692, "MLR 2017"), as amended. The framework applies a risk-based approach: identification and verification of the customer and beneficial owner, ongoing monitoring, and enhanced measures where the risk profile requires them.
Written policy covers customer risk assessment, source-of-funds and source-of-wealth analysis, politically exposed person (PEP) and sanctions screening, adverse-media review, record retention, staff training, and internal escalation of suspicious circumstances. The framework is reviewed at least annually and after any material change in guidance from the UK NCA, HMT, or the European Banking Authority.
- Customer due diligence (CDD) applied before mandate onboarding, per Regulation 27, MLR 2017
- Enhanced due diligence (EDD) applied to PEPs, high-risk third countries, and complex ownership structures, per Regulations 33–35, MLR 2017
- PEP, sanctions (OFSI, EU consolidated list, UN, OFAC), and adverse-media screening at onboarding and on an ongoing basis
- Source-of-funds and source-of-wealth documentation aligned with 5MLD Article 13(1)(c) and Recital 22
- Beneficial ownership identified to the 25%+ threshold under Regulation 5, MLR 2017; lower thresholds applied where risk indicates
- CDD and mandate records retained for the statutory five-year period following mandate closure, per Regulation 40, MLR 2017
- Written suspicious activity escalation procedure to the nominated officer, consistent with tipping-off restrictions
Every Realivo mandate applies risk-based CDD before any confidential information is exchanged. No exceptions on grounds of urgency, deal size, or introducer relationship.
KYC process and timelines
Know-Your-Customer clearance is the operational expression of the AML framework. Standard clearance targets three to five UK business days from receipt of a complete documentation stack. Enhanced due diligence — triggered by PEP status, complex or opaque ownership, high-risk jurisdictions, or unusual transaction structuring — targets ten to fifteen business days and may require additional independent verification.
The documentation stack is proportionate to the counterparty type (individual, corporate, trust, fund, family office) and the risk profile. Timelines start when the file is complete, not when the first document is received. Clients are given a written checklist upfront so that expectations, gating, and next steps are transparent from day one.
- Standard clearance: 3–5 UK business days on a complete file
- Enhanced clearance: 10–15 UK business days for EDD-triggered files
- Individual stack: government-issued photo ID, proof of address within three months, source-of-funds evidence, PEP self-declaration
- Corporate stack: certificate of incorporation, register of members and directors, UBO chart to natural persons, most recent filed accounts
- Trust or fund stack: trust deed or fund constitution, trustee/manager IDs, settlor and named beneficiary information, regulatory registration where applicable
- Ongoing monitoring: periodic re-verification, event-driven review, transaction consistency review against declared source of funds
Every Realivo counterparty receives the KYC checklist before commercial information is shared. Clearance is a gate, not a formality.
Data protection (UK GDPR and EU GDPR)
Realivo processes personal data under the UK GDPR (retained EU Regulation 2016/679 as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019) and, for data subjects in the EEA, under the EU GDPR (Regulation 2016/679). Processing is grounded in Article 6 lawful bases — principally legitimate interests (Article 6(1)(f)) for professional counterparty diligence, legal obligation (Article 6(1)(c)) for AML record-keeping, and contract performance (Article 6(1)(b)) where a mandate is in force.
Data minimisation, purpose limitation, and storage limitation (Article 5) are applied at collection and reviewed at scheduled intervals. Data subject rights under Articles 15–22 are honoured within the statutory one-month response window. Cross-border transfers rely on adequacy decisions or the UK International Data Transfer Agreement / EU Standard Contractual Clauses as required.
- Article 30 record of processing activities (ROPA) maintained and reviewed annually
- Data Processing Agreements (DPAs) in force with every processor — email infrastructure, CRM, document storage, e-signature, virtual data room, analytics
- Retention schedule: five years post-mandate for AML records, seven years for accounting records, otherwise the shortest reasonable period
- Subject access requests (SAR) acknowledged within 72 hours, substantive response within one calendar month per Article 12(3)
- Personal-data breach protocol: internal notification within 24 hours, ICO notification within 72 hours where required by Article 33
- Privacy notice published at realivo.com/privacy, updated when processing purposes change
Every Realivo mandate treats client data as regulated personal data first and commercial material second — including for corporate counterparties, whose director and UBO details are personal data under GDPR.
MiFID II conduct awareness (informed, not authorised)
Realivo Group Ltd is not a MiFID-authorised investment firm. It does not hold FCA Part 4A permission, is not passported into any EEA state, does not deal in financial instruments as principal or agent, does not provide investment advice within the meaning of Article 4(1)(4) of MiFID II (Directive 2014/65/EU), and does not carry out any of the regulated activities specified in Part II of the FCA Handbook Perimeter Guidance (PERG).
However, the conduct-of-business standards articulated in MiFID II — client best interest, fair treatment, clear and non-misleading communications, conflict identification and management, order handling transparency — inform how Realivo runs its non-regulated brokerage practice. The distinction is deliberate: sub-institutional real estate and business-sale brokerage sits outside the MiFID perimeter, so the firm cannot claim regulatory authorisation, but the professional standards it applies are drawn from that body of rules.
- No custody of client money or client assets under any circumstance
- No financial promotions within the meaning of section 21 of the Financial Services and Markets Act 2000 (FSMA); marketing materials describe brokerage services only
- No investment advice, portfolio management, or reception-and-transmission of orders in financial instruments
- Conflicts of interest register maintained; potential conflicts disclosed in writing before mandate signature
- Commission structure and any dual-representation arrangement disclosed in writing to the paying party at engagement
- Communications standard: written, dated, and archived; verbal indications followed by written confirmation on material points
Every Realivo mandate makes the regulatory perimeter explicit at engagement: what Realivo does (introduce, screen, structure, negotiate) and what it does not do (advise on investments, hold client assets, promote financial products).
Inside information, confidentiality, and information barriers
Off-market mandates and sub-institutional transactions frequently involve information that is price-sensitive, commercially sensitive, or personal — and, where a party is listed or in a pre-listed process, potentially inside information under Article 7 of the Market Abuse Regulation (Regulation (EU) 596/2014, "MAR") as onshored in the UK. Realivo's operating default is NDA-first: no substantive information is exchanged with a prospective counterparty until a written confidentiality agreement is executed.
Internal information handling is governed by written information barrier and need-to-know principles. Access to mandate files is restricted to the named deal team. Personal account dealing in identifiable listed securities that intersect with a live mandate is prohibited for the duration of the mandate and for a defined cooling-off period after closure.
- NDA signed before teaser, financial data, or counterparty identity is released
- Mandate-specific access lists: deal team identified in writing, no lateral sharing without written authorisation
- Physical and logical information barriers: separate storage folders, access-logged virtual data rooms, no shared inboxes across unrelated mandates
- Personal account dealing restrictions on securities within scope of a live mandate, with cooling-off period after mandate closure
- MAR awareness for any mandate touching listed or pre-listed entities, including insider list maintenance where the firm is placed on one by the client
- Confidentiality obligations survive mandate termination and remain enforceable under English law
Every Realivo mandate operates on the principle that a signed NDA is the entry ticket to information, not a formality that follows it.
Important note on scope
Realivo Group Ltd provides institutional brokerage services in respect of hotel, commercial real estate, business sale, and private client mandates. It does not provide investment advice, legal advice, tax advice, accountancy services, or regulated financial services of any kind; clients should retain their own independent professional advisers for those matters.
Frequently asked compliance questions
Is Realivo Group Ltd a regulated financial services firm?
Under which anti-money-laundering rules does Realivo operate?
How long does KYC take?
How does Realivo handle personal data?
Does Realivo hold client money or client assets?
What confidentiality protections apply to a mandate?
Compliance framework · PDF
The full Realivo compliance framework — registration, AML, KYC, data protection, MiFID II conduct standards, and confidentiality — in a single institutional PDF for counterparty files, legal review, and internal onboarding records.
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