⚠ Divatio Partners reserves the right to terminate discussions, decline mandates, and report suspicious activity to the relevant authorities at any stage and without prior notice.
Divatio Partners maintains strict standards regarding the parties with whom we transact. The following categories of enquiry will be declined immediately and without exception.
Prime Bank schemes, Private Placement Programs (PPPs), and High-Yield Investment Programs (HYIPs). We do not engage with any party promoting access to secret trading platforms, undisclosed banking arms of renowned institutions, or invitation-only programmes claiming above-market returns with no risk. These schemes — however they are branded — have been formally condemned as fraudulent by the FBI, the SEC, and the US Treasury Department. There are no secret markets in which banks trade instruments for privileged clients. Claims of extreme secrecy, non-disclosure requirements, and connections to top-tier banks are defining characteristics of this fraud. Enquiries of this nature will be declined immediately and may be reported.
Money laundering approaches. We do not engage with accounting firms, financial intermediaries, or any party seeking to facilitate the movement, layering, or placement of funds of unclear or illicit origin. Direct approaches with laundering propositions — however they are framed — will be reported to the relevant authorities without warning.
Fraudulent bullion and precious metals offers. We facilitate legitimate, market-priced bullion transactions. We do not entertain heavily discounted offers significantly beneath spot price — these are universally recognised indicators of fraud. Equally, any deal requiring payment for Safe Keeping Receipts (SKRs), upfront due diligence fees, or any form of advance payment before mandate verification is a hallmark of advance-fee fraud and will be declined and reported.
Fraudulent cryptocurrency and digital asset schemes. We do not participate in pump-and-dump schemes, fake token launches, fraudulent OTC crypto deals, or any digital asset transaction designed to obscure the origin or destination of funds. We do not deposit funds, execute trades, or custody assets on any third-party platform at the request of a counterparty. Requests to use a counterparty's "proprietary," "preferred," or "recommended" exchange — whether a cloned interface of a legitimate platform, a fabricated exchange, or an illiquid venue where the counterparty controls withdrawals — are treated as attempted custodial fraud and declined immediately. We trade exclusively on independently verified, regulated exchanges of our own choosing. Crypto-related enquiries are held to the same due diligence standards as physical commodity mandates.
Inexperienced or unverified professionals. We work exclusively with principals and seasoned intermediaries who can demonstrate a verifiable track record. Individuals unable to provide corporate documentation, references, or evidence of prior closed transactions will not be engaged.
Broker chains and unserious intermediaries. We do not participate in extended broker-to-broker chains, nor do we engage with parties who cannot demonstrate a direct relationship with the principal buyer or seller. Speculative mandates and time-wasting enquiries are declined on sight.
Politically Exposed Persons and government officials. We work exclusively with verified business professionals who manage their own end of a transaction. We do not entertain politicians, government ministers, state authorities, or individuals claiming political connections in order to secure favourable terms, expedite processes, or circumvent regulatory requirements. Deals contingent on political facilitation are declined without exception.
Triangular business structures. We do not accept convoluted multi-party arrangements designed to obscure the true origin of goods, the identity of principals, or the flow of funds. Every transaction we participate in must have a clear, auditable chain from source to destination.
Private jet meetings and theatrical deal staging. We do not accept invitations to fly by private jet to view or inspect commodities. These arrangements are a well-known hallmark of high-value fraud designed to create a false sense of legitimacy and urgency. Genuine deals do not require theatre.
Divatio Partners screens all counterparties, beneficial owners, and countries of origin against current OFAC, EU, and UN sanctions lists. Any match — whether direct or through associated entities — results in the automatic and immediate termination of discussions.
We do not accept transactions where goods are re-routed through third countries in order to circumvent origin restrictions or sanctions regimes. We require full disclosure of ultimate beneficial owners for all counterparties. Nominee structures, shell companies, or opaque holding arrangements without clear and verifiable UBO disclosure are not accepted.
Divatio Partners has direct experience with individuals claiming to operate as independent private bankers or external asset managers (EAMs) managing client portfolios under mandate de gestion, who in practice hold no clients, no assets under management, and no verifiable track record.
Since the entry into force of the Swiss Financial Institutions Act (FinIA) on 1 January 2020 — with a transition deadline of 31 December 2022 — all portfolio managers and trustees operating commercially in Switzerland are required to hold a FINMA licence and be affiliated with an authorised supervisory organisation. We are aware that this regulatory shift has been used by unqualified individuals as a pretext: citing the new licensing requirements as the reason they must "join" an established operation, when in truth they bring nothing — no clients, no declared assets, and no demonstrable competence.
Any independent banker, wealth manager, or EAM introduced to Divatio Partners or to our clients will be required to provide verifiable proof of their client base, declared assets under management, regulatory status, and FINMA licence or equivalent authorisation in their jurisdiction of operation. Failure to provide this will result in immediate termination of the introduction. We do not facilitate introductions of unverified financial intermediaries to our network under any circumstances.
We are aware that bad actors operating in the commodities and trade finance space routinely solicit company details, documentation, and corporate credentials from intermediaries under the guise of legitimate deal enquiries. These details are then used to impersonate firms, fabricate mandates, and defraud third parties.
Divatio Partners does not provide corporate documentation, letters of authority, or company credentials to unverified parties. Any request for such materials prior to the completion of our own due diligence process will be treated as a phishing attempt. If we determine that our company identity has been misused, we will pursue all available legal remedies.
Divatio Partners works with genuine trade finance instruments and maintains proven transaction methodologies developed through years of direct market experience. We do not publish, disclose, or discuss our procedures, structures, or instrument requirements with unverified parties.
This policy exists because we are acutely aware that fraudsters and bad actors actively seek to obtain legitimate methodologies in order to refine and lend credibility to their own schemes. Access to our transaction structures is granted only to fully verified counterparties within the context of a live, documented engagement.
We do not accept meetings in hotel rooms, informal venues, or any environment designed to isolate, pressure, or place our team or our clients in a vulnerable position. All in-person meetings take place in professional, neutral, and verifiable settings.
Divatio Partners does not respond to pressure tactics, artificial urgency, emotional manipulation, or any form of coercion. Our engagement timelines are dictated by the requirements of proper due diligence, not by the convenience of the counterparty. Attempts to bypass, rush, or manipulate our process will result in the immediate termination of discussions.
Divatio Partners conducts thorough due diligence on every prospective counterparty and transaction at our own cost. We never charge fees for due diligence, nor do we accept deals where we are asked to pay for due diligence, SKRs, or any form of verification conducted by the other party. Legitimate business does not require the paying party to fund the seller's compliance obligations.
All prospective counterparties are subject to verification of corporate registration, beneficial ownership, source of funds or goods, and compliance with applicable sanctions regimes. We reserve the right to request additional documentation at any stage and to withdraw from discussions where satisfactory verification cannot be obtained.
Divatio Partners proactively studies the export and import regulations, licensing frameworks, and legal procedures of every frontier and developed market in which we operate. We do not rely on counterparties to educate us on local requirements — we verify independently.
We do not accept mining licences for concessions whose claimed output exceeds what is geologically possible for the stated area and deposit type. We work with refineries that monitor and, in most cases, physically inspect the mines from which material originates. We conduct or commission our own site verification where required.
Photographs of gold or precious metals in unsecured locations, informal settings, or originating from nonproducing countries or countries under international sanctions will result in the immediate termination of discussions without notice.
Divatio Partners does not knowingly source from conflict zones or from mining operations that directly or indirectly finance armed groups, criminal organisations, or non-state militias. We require a verifiable chain of custody from mine to refinery for all physical commodity transactions.
We only transact material processed through LBMA-accredited or equivalent internationally recognised refineries. All assay must be conducted by independent, accredited laboratories. We do not accept selfcertified purity claims or unverifiable refinery documentation.
Divatio Partners aligns its sourcing practices with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. We acknowledge that these frameworks are written by institutional bodies and are not always perfectly adapted to the operational realities of artisanal and semi-industrial mining. Where full compliance is impractical, we align to the greatest extent possible while prioritising adherence to the logistics and export laws of the jurisdictions in which we operate.
We do not work with mines that operate illegally or whose legitimacy cannot be verified. We do not engage with mining operations that fail to meet the following minimum standards:
Fair compensation. Miners must receive a salary, wage, or equivalent compensation for their labour. We do not work with operations that exploit unpaid or indentured labour in any form.
No child labour. Children must not be employed in mining operations. Where children are present on site — as is common when women in the workforce have no alternative childcare — the operation must provide appropriate facilities, safety measures, and welfare provisions for those children.
Long-term worker welfare. Mining operations must provide some form of pension, profit-sharing, proprietary stake, or long-term financial security arrangement for their workers. Extraction without redistribution is exploitation.
Indigenous and ancestral community empowerment. We believe in the fair redistribution of value to the communities from whose land minerals are extracted. We actively support the progression from ancestral and artisanal mining through semi-industrial to fully industrial operations, ensuring that indigenous and local communities retain meaningful economic participation throughout that transition.
Environmental responsibility. Mining operations must comply with local environmental permits and must not engage in practices causing deliberate deforestation, river contamination, or uncontrolled use of mercury amalgamation. Divatio Partners offers environmental consulting services through its partner network to assist mining operations in meeting and exceeding environmental standards.
All deal-related communication must be conducted via verifiable corporate channels — registered business email, documented corporate telephone lines, or established secure platforms. We do not conduct substantive deal discussions solely via personal messaging applications, anonymous email providers, or unverifiable channels.
All material terms, commitments, and agreements must be documented in writing. No commitment, obligation, or agreement of any kind exists until formalised in a signed written contract between the parties. Verbal representations, handshake agreements, and informal understandings carry no legal or commercial weight.
Divatio Partners does not grant exclusivity periods, sign letters of intent, or hold mandates open for parties who have not completed our verification process. We engage on our terms and within our timelines.
We accept no liability for parties introduced by third-party intermediaries. All introduced counterparties are subject to the same due diligence standards regardless of the referrer's reputation or relationship with our firm.
Divatio Partners possesses deep, operational knowledge of physical commodity supply chains, trade finance structures, and cross-border logistics built through years of direct market participation. This expertise is our competitive edge.
We do not provide education, training, mentorship, or consulting on our transaction methodologies to external parties. We do not sell courses, guides, or instructional materials. Enquiries of this nature will not receive a response.
Divatio Partners operates in full compliance with the UK Bribery Act 2010. We do not offer, promise, give, request, or accept bribes or facilitation payments in any form, whether directly or through intermediaries. This applies to all jurisdictions in which we operate, regardless of local custom or practice.
Divatio Partners reserves the right to suspend or terminate any engagement where political instability, civil unrest, regulatory changes, or force majeure events in the country of origin compromise the integrity, legality, or safety of the transaction. We are under no obligation to continue a deal where conditions on the ground have materially changed.
All counterparty information collected during our due diligence process is held in strict confidence and processed in accordance with applicable data protection laws, including the UK General Data Protection Regulation. Information is used solely for the purposes of evaluating and conducting transactions and is not disclosed to third parties without the express consent of the data subject, except where required by law or regulatory obligation
Divatio Partners operates in full compliance with UK anti-money laundering regulations and international sanctions frameworks. Where we identify or reasonably suspect fraudulent, criminal, or sanctioned activity, we are obligated to report to the appropriate authorities and will do so without notifying the party concerned.
All engagements with Divatio Partners Limited are governed by the laws of England and Wales and are subject to the exclusive jurisdiction of the courts of England and Wales. No alternative jurisdiction or governing law will be accepted without a prior written agreement executed by both parties.
We welcome serious, professional enquiries from principals and experienced intermediaries operating in physical commodities, digital assets, trade finance, and consulting. If your business is legitimate, well-documented, and conducted in good faith, we look forward to hearing from you.