AB and AML Policy


Tavares Castilho, Rodrigues e Associados – Sociedade de Advogados SP RL, operating under the commercial name of Castilho International Law Firm is law firm and provides legal advice and assistance to its clients. It is regulated by the Ordem dos Advogados. The personal data that Castilho International Law Firm processes to provide these services relates to its clients and other individuals as necessary, including staff and suppliers’ staff. 

Advisory Board

Despite our best efforts, from time to time inadvertent breaches of guidelines do occur. When guideline deviations arise, we seek to bring the client's account back into compliance as promptly as possible. If the deviation incident is deemed to be an error, we will follow the escalation and correction procedures outlined in our Error Resolution and Reporting Policy. Whenever we become aware of a potential error (whether we or our client are the first to notice it) we will conduct a thorough investigation. Where a guideline error on our part has generated a loss for our client, we shall make our client's account whole, and inform our client promptly. We note that some of our clients have expressly incorporated into their IMA protocols for the timeliness with which they should be notified of any such breach as well as guidance for handling the breach.

 It is AB's policy to record all incidents involving the accounts of asset management clients and to correct any errors affecting those accounts in a fair, timely and reasonable manner. When correcting an error, our objective is always to take appropriate actions consistent with our fiduciary duty of care, to put our client in the same or substantially the same position as if we had not made the error. In some cases, that is not possible or practical. Even then, however, if our client has incurred a loss attributable to the actions of AB, that loss is fully reimbursable.

Anti Money Laundry

In accordance with Portuguese Law number 83/2017, legal offices are obliged to participate to the authorities any suspicion of money laundry and further prohibits lawyers from revealing to the client information, documents, investigations or inquiries related to those crimes. These professionals will also have to comply with the duty of communication to the Central Department of Investigation and Criminal Action (DCIAP), and to the Financial Information Unit of the Judiciary Police with the information they have at the moment.

Monitoring and review

This policy was last updated on 17 March 2019 and shall be regularly monitored and reviewed, at least every two years.