QA Test Holdings Ltd

Corporate client - reference 100006

Active

Onboarding lifecycle

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

Current status: Active
Current step: Approved
Assigned reviewer: Trevor Clein
Enhanced due diligence: Required
Prepared by: Asher Freed
Decision reason: MLRO second-line approval: EDD file reviewed, source of funds and ownership evidenced, relationship accepted.

Risk assessment

iFAST floor

High

LionGM rule

High

Final applied risk

High

EDD required

Yes

Owner: Trevor Clein
Review cadence: 12 months
Next review due: 2027-07-17
Country risk version: 2026-04
Industry risk version: 2026-04
Decided by: Asher Freed

Rationale

Industry "FX Business" maps to "FX Business" (score 12), base risk High. Material link outside core geographies (UK, EU/EEA, Hong Kong, Israel), enhanced due diligence applies. iFAST floor risk High applied as the minimum.

Corporate CDD questionnaire

Legal name: QA Test Holdings Ltd
Trading name: Not provided
Registration number: QA-0000001
Incorporation date: Not provided
Jurisdiction: United Kingdom
Registered office: Not provided
Principal place of business: Not provided
Website: Not provided
Business email: Not provided
Business telephone: Not provided
Tax number: Not provided
Nature of business: Foreign exchange and cross-border payments
Detailed activity: Not provided
Main products and services: Not provided
Main countries of operation: United Arab Emirates; Hong Kong
Services requested: Not provided
Expected monthly value: 250,000GBP
Expected largest transaction: 50,000GBP
Main currencies: Not provided
Expected source countries: United Arab Emirates
Expected beneficiary countries: Hong Kong
Documents received: Not provided
Ownership structure: Not provided
Nominee structure: Not provided
Source of funds: Trading revenue
PEP exposure: No
Sanctions exposure: No
Adverse media: No
Third-party intermediary: Not provided
Gambling exposure: Not provided
Funding account verified: Not provided
First transaction support obtained: Not provided

Directors, shareholders and beneficial ownership

QA Test Holdings Ltd
Registered in United Kingdom
- Jordan Vale
  Director, Authorised Signatory - British national
- Morgan Reef
  UBO, Shareholder - British national
  60%

Internal compliance checklist

#	Item	Status	Owner	Notes
1	Identity and verification (Sumsub planned, verified manually)	Completed	Asher Freed	Identity checked against the government photo identity document.

Documents obtained

Kind	File	Version	SHA-256	Uploaded by
Certificate of incorporation	qa-holdings-coi.pdf	v1	b0e59c26092fcf0d...	Asher Freed
Register of directors	qa-holdings-directors.pdf	v1	2f0c841dfb84ea1c...	Asher Freed
Passport (UBO)	morgan-reef-passport.pdf	v1	8d8debb1d5af14e3...	Asher Freed

Screening

Result: Pass
Category: None
List version: ComplyAdvantage list snapshot 2026-04
Checked at: 2026-07-17
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
2026-07-17	Out	USD 9,000	GBP 7,110	United Kingdom to United Arab Emirates	New Beneficiary FZEUrgent instruction, beneficiary changed after login anomaly. Suspected account takeover / payment redirect.	Held

Monitoring alerts

R8 - Account takeover / payment redirectHighUnderReview
GBP 7,110
Outbound payment of GBP 7,110 to a changed beneficiary (New Beneficiary FZE) 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

Periodic review history

Due date	Risk level	Status	Owner	Trigger event	Outcome
2027-07-17	High	Due	Trevor Clein	Onboarding risk assessment	Pending

Decision history

When	Event	Actor	Detail
17 Jul 2026, 12:04	Approved	Trevor Clein	Active MLRO second-line approval: EDD file reviewed, source of funds and ownership evidenced, relationship accepted.
17 Jul 2026, 12:04	Submitted for review	Asher Freed	PendingReview Onboarding file submitted for Trevor Clein decision.
17 Jul 2026, 12:04	Risk assessed	Asher Freed	High (EDD Yes, reviewer Trevor Clein) Industry "FX Business" maps to "FX Business" (score 12), base risk High. Material link outside core geographies (UK, EU/EEA, Hong Kong, Israel), enhanced due diligence applies. iFAST floor risk High applied as the minimum.

Audit trail

Append-only

When	Action	Actor	Change	Basis
17 Jul 2026, 12:04	Transaction booked	Trevor Clein	Out USD 9,000 (GBP 7,110) to New Beneficiary FZE Transaction booked; monitoring re-run raised 1 new alert(s).	Policy 2026-04
17 Jul 2026, 12:04	Alert raised	Trevor Clein	R8 (High) Outbound payment of GBP 7,110 to a changed beneficiary (New Beneficiary FZE) after an account anomaly. Payment-redirect fraud red flag. Hold and verify by independent callback before any release.	Policy 2026-04 anti_fraud (red flags: account takeover, payment redirection, invoice and mandate fraud)
17 Jul 2026, 12:04	Approved	Trevor Clein	PendingReview to Active MLRO second-line approval: EDD file reviewed, source of funds and ownership evidenced, relationship accepted.	Policy 2026-04
17 Jul 2026, 12:04	Submitted for review	Asher Freed	RiskAssessed to PendingReview Onboarding file submitted for Trevor Clein decision.	Policy 2026-04
17 Jul 2026, 12:04	Risk assessed	Asher Freed	Screening to High (EDD Yes, reviewer Trevor Clein) Industry "FX Business" maps to "FX Business" (score 12), base risk High. Material link outside core geographies (UK, EU/EEA, Hong Kong, Israel), enhanced due diligence applies. iFAST floor risk High applied as the minimum.	Policy 2026-04 2026-04/2026-04