Disclosures and counterparty terms.
The terms below describe the firm's capacity, its handling of conflicts and sanctions screening, its data-handling and engagement-confidentiality posture, and the standing complaint channel. They are the standing public disclosures of Riffington Capital Ltd.
Capacity
Riffington Capital Ltd. acts as principal in every transaction. The firm is not a broker, agent, contingency collector, or fiduciary for the seller. Submissions create no advisory or attorney-client relationship.
Conflicts of interest
The firm maintains a written conflicts register. Counterparties and underlying debtors are screened against the register at intake. Where a screened conflict is identified, the firm declines the file rather than seek a waiver.
Sanctions and financial-crime
Every counterparty and every named debtor is screened against OFAC, OFSI, EU consolidated, and UN sanctions lists. Beneficial-ownership verification is performed on the seller entity. Politically exposed persons are escalated. Files that cannot clear screening are declined and closed.
Data handling
Submitted documentation is held in an access-controlled environment. Access is limited to firm personnel and retained counsel directly involved in portfolio review. Documents from declined portfolios are destroyed within thirty days of decline, unless the seller requests their return. A Data Processing Addendum is available for sellers subject to GDPR, UK GDPR, or equivalent.
Engagement confidentiality
The existence of a submission, the terms of any offer, and the identity of the seller are confidential. The firm does not disclose counterparty identities except as required by law, and does not publish case studies or client names.
No solicitation
Materials on this site are informational only. Nothing on the site is an offer to purchase, a solicitation of any security, legal advice, or a binding indication of value. All offers are made by separate written instrument signed by an authorized officer of Riffington Capital Ltd.
Complaints
Counterparties and underlying debtors may direct complaints in writing to compliance@riffington.com. Receipt is acknowledged within two business days; a substantive response is generally provided within ten business days.