Disclaimer
Aster & Trujillo provides this statement in the interest of legal clarity, regulatory compliance, and to avoid any misinterpretation regarding the structure and responsibilities within the firm.
Directorship and Regulatory Authority
The only individuals legally appointed as Directors of Aster & Trujillo are:
- Mr. Luis E. Trujillo Garzon, Managing Partner & Director
- Ms. Elena Violeta Dragodan, Managing Partner & Director
These individuals are the sole persons vested with legal authority over the management and operation of the firm. Both have successfully completed the Fit and Proper Person Test in accordance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, and are formally designated as the firm’s AML Compliance Officers and Responsible Persons.
They are responsible for overseeing the firm’s anti-money laundering policies and procedures, including customer due diligence (CDD), Know Your Client (KYC) protocols, internal risk assessments, staff training, and external reporting obligations.
Use of Titles Within the Firm
Certain job titles used across our website and internal communications—such as “Director”, “Accounts Director”, “Manager”, or “Account Manager”—are applied for internal purposes only. These titles reflect roles within our employment structure and do not confer:
- Statutory directorship or decision-making authority under the Companies Act 2006
- Control or significant influence under AML legislation or the Senior Managers and Certification Regime (SM&CR)
- Responsibility for regulatory compliance, client risk management, or governance
- Any right to LLP profits, drawings, dividends through our group of companies, or beneficial ownership in the firm
Employee Status and Professional Standards
All team members at Aster & Trujillo operate strictly under contractual employment and are subject to rigorous internal procedures and continuous professional development, including:
- Annual and role-specific AML and compliance training
- Ongoing Continuing Professional Development (CPD) aligned with relevant legislation and industry standards
- Full adherence to our data protection, confidentiality, and client care protocols
These measures ensure that while our employees support the day-to-day operation of the firm, no employee outside of the named Directors holds any statutory or regulatory responsibility under applicable AML or corporate governance legislation.
This disclaimer is issued to reaffirm our commitment to legal and regulatory transparency and to satisfy supervisory expectations under UK law, including those of HMRC, OPBAS, and affiliated professional and regulatory bodies.