Compliance
Small by design, so the posture can be simple.
A recovery practice touches invoices, contracts and operational records, and never touches money. That boundary does most of the compliance work, and it is a design decision rather than a control bolted on afterwards.
Non-custodial
The boundary that matters most
Xvilan never takes custody of, holds, or transfers client funds. Recoveries are credited by the supplier directly to the airline. We are not a payment institution and hold no client accounts, which keeps the engagement outside money-transmission entirely rather than inside it under an exemption.
Evidence-led
Nothing is claimed that cannot be shown
Every finding carries the line, the amount billed, the amount properly due and the basis of the difference. A supplier can test any claim against their own paper and the operational record, and so can an auditor. Nothing is asserted on the strength of our model alone.
Confidential by default
Client data is the client's
Contracted rates, invoices and findings belong to the client. They are not pooled, resold or used to price another engagement. The reference rate library is built from sources public to us; a client's own rates never enter it.
Auditable record
Every action is logged
Findings, filings, acceptances and recoveries are recorded with who did what and when, so an engagement can be reconstructed from the record rather than from memory. Suppliers receive their claims through a portal that shows them exactly what was filed against them.
What we do not claim
Naming the gaps is more useful than padding the list. If a control is required for your procurement process and is not below, ask, and we will tell you plainly whether we hold it.
We are not SOC 2 Type II certified.
We do not hold the report and will not imply otherwise. Our controls are described here in plain terms for scrutiny on their merits.
We are not a payment institution.
We neither hold nor move client money. Fees are invoiced against recoveries already credited to the client.
We do not guarantee a recovery.
We guarantee the evidence and the work behind a finding; whether a supplier credits it depends on the supplier.
We do not replace your auditors or your tax advice.
An engagement identifies amounts charged above what was due. Treatment of a recovery in your accounts is a matter for your own advisers.
Regulatory awareness
Emissions cost work is reconstructed from actual uplift and route data against the schemes that apply — EU ETS, UK ETS and CORSIA — on the principle that an obligation you can rebuild yourself is an obligation you can check. These schemes are new enough that billing practice is still inconsistent, and the check is where the discrepancy shows.
Engagements are governed by the laws of the State of Wyoming, and the terms that govern one are published in full before anyone is asked to accept them.