Ethics & Compliance
Lycia's compliance framework is not a regulatory obligation — it is a strategic commitment to conducting business in a manner that protects our clients, our counterparties and the markets in which we operate.
"Lycia's commitment to ethical business conduct is absolute. We will not advise on, facilitate or participate in any activity that violates applicable law, our internal compliance standards or our sense of what responsible business conduct requires. This is not a compliance position — it is a business philosophy."
Lycia Limited — Management Statement on Ethics
Our Compliance Framework
Lycia's compliance programme covers the full range of legal and regulatory obligations applicable to an advisory and trade facilitation firm operating in international markets. Each area of the programme is governed by a written policy, supported by defined procedures and subject to periodic review.
Anti-Bribery & Anti-Corruption
Lycia operates in full compliance with the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act. All principals, staff, agents and intermediaries are required to comply with our zero-tolerance anti-bribery policy. We do not make, offer or accept facilitation payments under any circumstances. All third-party intermediary relationships are subject to enhanced due diligence and formal written agreements that incorporate anti-bribery representations.
Anti-Money Laundering (AML)
Lycia's AML programme is designed to prevent the firm's advisory and commercial services from being used to facilitate money laundering or the financing of terrorism. Our AML controls include client risk assessment, source-of-funds verification for significant transactions, transaction monitoring and mandatory reporting obligations. The programme is reviewed and updated annually in line with FATF guidance and UK regulatory requirements.
Know Your Customer (KYC)
All individual clients, beneficial owners and key counterparties are subject to KYC screening before engagement commencement. KYC procedures include identity verification, PEP (Politically Exposed Person) screening, adverse media review and sanctions checking against OFAC, UN, EU and HM Treasury sanctions lists. Enhanced KYC applies to clients and counterparties classified as high-risk.
Know Your Business (KYB)
Corporate clients, suppliers, buyers and partners are subject to KYB screening, including corporate structure verification, ultimate beneficial ownership confirmation, regulatory licence checks and reputational due diligence. KYB is refreshed on a periodic basis and triggered by material changes to client or counterparty circumstances.
Counterparty Due Diligence
Before facilitating any introduction, trade transaction or commercial arrangement, Lycia conducts proportionate due diligence on all counterparties. This includes sanctions screening, adverse media review, business reputation assessment and — for high-value or high-risk counterparties — enhanced documentary review. We will decline to facilitate transactions where counterparty due diligence cannot be completed satisfactorily.
Conflict of Interest Management
Lycia maintains a Conflicts Register that records all actual and potential conflicts arising from client relationships, partner arrangements and personal interests of principals and staff. Identified conflicts are assessed by senior management and addressed through disclosure, mitigation or — where a conflict is material and unresolvable — declination of the relevant engagement or relationship.
Supplier & Partner Verification
All material suppliers, sub-contractors and delivery partners are subject to pre-engagement verification covering compliance standing, relevant licences and registrations, beneficial ownership, and reputational assessment. Supply chain relationships are managed under formal written agreements incorporating compliance representations.
Confidentiality & Data Protection
Client information, commercial intelligence and personal data are managed under strict confidentiality protocols. Lycia complies with UK GDPR and all applicable data protection legislation. Client data is stored securely, access is restricted on a need-to-know basis, and our confidentiality obligations survive the termination of any client engagement without time limitation.
Whistleblowing & Reporting
Lycia maintains a confidential whistleblowing facility through which principals, staff and third parties can report concerns about compliance, ethics or conduct without fear of retaliation. All reports are reviewed by senior management, investigated proportionately and responded to in a defined timeframe. Whistleblowers are protected in accordance with the Public Interest Disclosure Act 1998 and our internal whistleblowing policy.
Compliance as a Competitive Advantage
In the markets where Lycia operates, rigorous compliance is not merely a regulatory obligation — it is a commercial differentiator. Governments, institutional investors and multinational corporations operating in African markets face intense scrutiny from regulators, shareholders and counterparties regarding the compliance standards of their advisors and business partners.
By maintaining the highest standards of compliance across every aspect of our operations, Lycia enables its clients to engage in African markets with confidence that their advisors meet the expectations of the most demanding international compliance frameworks.
Our compliance culture is embedded at the leadership level. Every principal is personally accountable for compliance within their area of responsibility, and compliance performance is assessed as part of our regular management review processes.
Compliance Enquiries
For enquiries about Lycia's compliance programme or to submit a compliance-related request, contact us directly.