VERIFICATION

Counterparty due diligence, seven sequential phases. Every one cleared before a counterparty reaches your desk.

01Sanctions

02Registry

03Ownership

04Address

05Web

06Adverse

07Plausibility

GREEN0.89

■ cleared · ■ fail any gate → blocked, never delivered

PHASES

01SANCTIONSOFAC (SDN + Consolidated), EU Consolidated, UK OFSI, UN Security Council, OSFI, DFAT. Fuzzy and transliteration matching across the entity and its principals.

02REGISTRYLegal entity status, registered office, and officers confirmed against the corporate registry in the claimed jurisdiction. Cross-jurisdictional cross-check.

03BENEFICIAL OWNERSHIPOwnership graph resolved to ultimate beneficial owners at the 25% threshold; every principal re-screened against the sanctions lists from phase one.

04ADDRESSRegistered office resolution, mass-registration and virtual-office flagging, and operational premises verification where claimed.

05WEB PRESENCEDomain, SSL, industry press, and trade-reference footprint. Shell-structure and dormancy signal detection.

06ADVERSE MEDIALitigation, enforcement actions, fraud reporting, and politically-exposed-person exposure across news and regulatory sources.

07PLAUSIBILITYVolume, pricing, routing, logistics, and payment structure assessed for economic coherence and fraud typology.

DECISION MATRIX

PHASE	PASS	REVIEW	BLOCK
Sanctions	Continue	—	Halt + escalate
Registry	Continue	Request documents	Halt
Beneficial Ownership	Continue	Request UBO declaration	Halt + escalate
Address	Continue	Alternative evidence	Halt
Web Presence	Continue	Flag to desk	Halt
Adverse Media	Continue	Flag to desk	Halt
Plausibility	Continue	Clarify	Halt

RECORD

Each check, source, and decision is written to an append-only audit log and retained per statutory record-keeping requirements. Records are available under mandate and to regulators on request.

LIMITATIONS

Screening reduces risk; it does not eliminate it. Sanctions designations update on schedule and may lag by hours. Registries reflect filings made by the companies themselves. Counterparties remain responsible for their own compliance obligations.

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