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Corporate client - reference 100008
Industry "Money services business" maps to "FX Business" (score 12), base risk High. iFAST floor risk High applied as the minimum.
| # | Item | Status | Owner | Notes |
|---|---|---|---|---|
| 1 | Identity and verification (Sumsub planned, verified manually) | Completed | Asher Freed | Identity checked against the government photo identity document. |
| Kind | File | Version | SHA-256 | Uploaded by |
|---|---|---|---|---|
| Certificate of incorporation | coi.pdf | v1 | a07fce1131426aa2... | Asher Freed |
| Passport | director-passport.pdf | v1 | 62c7556a2d9c9f8f... | Asher Freed |
Book a transaction to test the client against the monitoring rules. The engine re-runs over the full history and raises any new alert.
Outbound payment of GBP 8,500 to a changed beneficiary (New Beneficiary Holdings) after an account anomaly. Payment-redirect fraud red flag. Hold and verify by independent callback before any release.
| Due date | Risk level | Status | Owner | Trigger event | Outcome |
|---|---|---|---|---|---|
| 2027-07-17 | High | Due | Trevor Clein | Onboarding risk assessment | Pending |
| When | Event | Actor | Detail |
|---|---|---|---|
| 17 Jul 2026, 12:44 | Approved | Trevor Clein | Active MLRO approval after EDD review |
| 17 Jul 2026, 12:44 | Submitted for review | Asher Freed | PendingReview Onboarding file submitted for Trevor Clein decision. |
| 17 Jul 2026, 12:44 | Risk assessed | Asher Freed | High (EDD Yes, reviewer Trevor Clein) Industry "Money services business" maps to "FX Business" (score 12), base risk High. iFAST floor risk High applied as the minimum. |
| When | Action | Actor | Change | Basis |
|---|---|---|---|---|
| 17 Jul 2026, 12:44 | Transaction booked | Trevor Clein | Out GBP 8,500 (GBP 8,500) to New Beneficiary Holdings Transaction booked; monitoring re-run raised 1 new alert(s). | Policy 2026-04 |
| 17 Jul 2026, 12:44 | Alert raised | Trevor Clein | R8 (High) Outbound payment of GBP 8,500 to a changed beneficiary (New Beneficiary Holdings) 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, 12:44 | Approved | Trevor Clein | PendingReview to Active MLRO approval after EDD review | Policy 2026-04 |
| 17 Jul 2026, 12:44 | Submitted for review | Asher Freed | RiskAssessed to PendingReview Onboarding file submitted for Trevor Clein decision. | Policy 2026-04 |
| 17 Jul 2026, 12:44 | Risk assessed | Asher Freed | Screening to High (EDD Yes, reviewer Trevor Clein) Industry "Money services business" maps to "FX Business" (score 12), base risk High. iFAST floor risk High applied as the minimum. | Policy 2026-04 2026-04/2026-04 |
| 17 Jul 2026, 12:44 | Screening completed | Asher Freed |
| Draft to Screening (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 |
| 17 Jul 2026, 12:44 | Identity verified | Asher Freed | Verified (manual) Identity and verification step completed. Automated provider (Sumsub) is planned, not live. | Policy 2026-04 |
| 17 Jul 2026, 12:44 | Documents recorded | Asher Freed | Certificate of incorporation: coi.pdf; Passport: director-passport.pdf 2 document(s) captured and hashed. | Policy 2026-04 |
| 17 Jul 2026, 12:44 | Draft created | Asher Freed | Draft Draft corporate onboarding file opened for Sentinel QA Global Trading Ltd. | Policy 2026-04 |