Reportly Limited

Corporate client - reference 100003

Active

Onboarding lifecycle

1Draft
2Screening
3Risk assessed
4Pending review
5Active

Current status: Active
Current step: Not recorded
Assigned reviewer: Asher Freed
Enhanced due diligence: Not required
Prepared by: Seeded sample
Decision reason: Not provided

Risk assessment

iFAST floor

Low

LionGM rule

Medium

Final applied risk

Medium

EDD required

Owner: Asher Freed
Review cadence: 24 months
Next review due: 2028-07-17
Country risk version: 2026-04
Industry risk version: 2026-04
Decided by: Asher Freed

Rationale

Industry "Business and domestic software development" maps to "Information and communication" (score 0), base risk Low. Country "Israel" (Medium banding) raises risk to Medium. Lion rule risk (Medium) exceeds the iFAST floor (Low), strictest applies.

LionGM risk sits above the iFAST floor. The strictest rule applies.

Corporate CDD questionnaire

Legal name: Reportly Limited
Trading name: Not provided
Registration number: 17121068.0
Incorporation date: 2026-03-27 00:00:00
Jurisdiction: UK
Registered office: Enterprise House, First Floor, 2 The Crest, London, United Kingdom, NW4 2HN
Principal place of business: Enterprise House, First Floor, 2 The Crest, London, United Kingdom, NW4 2HN
Website: https://en.twinnovation.eu/
Business email: michal@twinnovation.eu
Business telephone: 972 543 999 980
Tax number: 16158 17442
Nature of business: Business and domestic software development
Detailed activity: Not provided
Main products and services: Not provided
Main countries of operation: Not provided
Services requested: Not provided
Expected monthly value: Not provided
Expected largest transaction: Not provided
Main currencies: GBP, EUR, ILS
Expected source countries: UK
Expected beneficiary countries: Israel, UK
Documents received: Certificate Of Incorporation - IN01
Ownership structure: Direct
Nominee structure: No
Source of funds: Not provided
PEP exposure: No
Sanctions exposure: No
Adverse media: No
Third-party intermediary: No
Gambling exposure: No
Funding account verified: Yes
First transaction support obtained: Yes

Directors, shareholders and beneficial ownership

Reportly Limited
Registered in UK
- Michal Zilberberg
  Director, Shareholder, UBO, Authorised Signatory - Lithuanian passport 25656051
  100%

Internal compliance checklist

#	Item	Status	Owner	Notes
1	Certificate of incorporation / registration obtained	Pending	Onboarding	-
2	Recent registry extract / profile report obtained	Pending	Onboarding	-
3	Articles / constitutional documents obtained	Pending	Onboarding	-
4	Directors register obtained	Pending	Onboarding	-
5	Shareholders register / register of members obtained	Pending	Onboarding	-
6	UBO declaration completed	Pending	Onboarding	-
7	Ownership chart / structure reviewed	Pending	Onboarding	-
8	Authorized signatories identified and verified	Pending	Onboarding	-
9	Board resolution / authority to act obtained	Pending	Onboarding	-
10	Business activity verified	Pending	Onboarding	-
11	Expected transaction profile recorded	Pending	Onboarding	-
12	Source of corporate funds reviewed	Pending	Onboarding	-
13	Source of wealth for UBO(s) reviewed if required

Documents obtained

Kind	File	Version	SHA-256	Uploaded by
Certificate of incorporation	reportly-IN01-17121068.pdf	v1	83b3cb91daeaede4...	Asher Freed

Screening

Result: Pass
Category: None
List version: ComplyAdvantage list snapshot 2026-04
Checked at: 2026-04-20
Reviewer: Asher Freed
Notes: Customer declared no sanctions, politically exposed person or adverse-media exposure.

Transaction monitoring

Book a transaction to test the client against the monitoring rules. The engine re-runs over the full history and raises any new alert.

Transactions

Date	Dir	Original	GBP equivalent	Corridor	Counterparty	Status
2026-07-15	Out	GBP 9,850	GBP 9,850	UK to UK	Supplier (bank details changed)Account takeover: supplier bank details changed after a login from a new device, then an urgent payment instruction outside the usual pattern. Payment-redirect fraud red flag.	Posted
2026-07-12	In	GBP 15,000	GBP 15,000	UK to UK	Enterprise licence paymentSingle high-value receipt above the GBP 10,000 threshold.	Held
2026-06-27	In	GBP 4,000	GBP 4,000	UK to UK	Client invoice (software)	Posted
2026-05-28	In	EUR 4,500	GBP 3,825	UK to Israel	Client invoice (software)	Posted
2026-04-28	In	GBP 4,000	GBP 4,000	UK to UK	Client invoice (software)	Posted

Monitoring alerts

R8 - Account takeover / payment redirectHighUnderReview
GBP 9,850
Outbound payment of GBP 9,850 to a changed beneficiary (Supplier (bank details changed)) after an account anomaly. Payment-redirect fraud red flag. Hold and verify by independent callback before any release.
Routed to Trevor CleinRule basis: anti_fraud (red flags: account takeover, payment redirection, invoice and mandate fraud)1 linked transaction
R1 - High-value single transactionHighUnderReview
GBP 15,000
Single transaction of GBP 15,000 at or above the GBP 10,000 threshold (Enterprise licence payment). EFTR relevance recorded.
Routed to Trevor CleinRule basis: onboarding_tm_procedure section 11; ra_pcp EFTR1 linked transaction

Periodic review history

Due date	Risk level	Status	Owner	Trigger event	Outcome
2026-08-26	Medium	Due	Asher Freed	Scheduled review	Pending

Decision history

No decision events yet

Risk assessment, review submission and the approval or rejection are recorded here as they happen.

Audit trail

Append-only

When	Action	Actor	Change	Basis
17 Jul 2026, 11:32	Customer onboarded	Asher Freed	Active CDD completed	Policy 2026-04
17 Jul 2026, 11:32	Screening completed	Asher Freed	Pass Customer declared no sanctions, politically exposed person or adverse-media exposure. Independent list screening (ComplyAdvantage) is planned and not yet live, so the automated screening checklist items remain outstanding.	Policy 2026-04 ComplyAdvantage (planned) list snapshot 2026-04