Viktor Petrov

Individual client - reference 100015

Rejected

Onboarding lifecycle

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

This relationship was not opened. Current status: Rejected.

Current status: Rejected
Current step: Rejected
Assigned reviewer: Trevor Clein
Enhanced due diligence: Required
Prepared by: Trevor Clein
Decision reason: prohibited jurisdiction linked to the relationship: Russia

Risk assessment

iFAST floor

Prohibited

LionGM rule

Prohibited

Final applied risk

Prohibited

EDD required

Yes

Owner: Trevor Clein
Review cadence: 0 months
Next review due: 2026-07-17
Country risk version: 2026-04
Industry risk version: 2026-04
Decided by: Trevor Clein

Rationale

Onboarding refused, prohibited jurisdiction linked to the relationship: Russia. Under the strictest-rule principle this restriction cannot be overridden. Escalated to the MLRO. LionGM does not accept this relationship.

Individual CDD questionnaire

Full name: Viktor Petrov
Date of birth: 02/02/1968
Nationality: Russian
Country of birth: Russia
Residential address: Tverskaya Street, Moscow, Russia
Telephone: Not provided
Email: Not provided
Occupation: Government advisory consultant
Employer: State-linked advisory office
Tax residence: Russia
Tax identification number: RU7788990
Identity document type: Passport
Identity document number: 712233445
Issuing country: Russia
Issue date: Not provided
Expiry date: 10/10/2029
Proof of address: Not provided
Purpose of relationship: Not provided
Services requested: Cross-border payments
Expected source countries: Russia
Expected beneficiary countries: United Kingdom, Cyprus
Expected monthly value: 80,000 USD
Expected largest transaction: 80,000 USD
Expected frequency: Not provided
Source of funds: Consulting fees
Source of funds detail: Advisory fees paid from overseas accounts
Acting for own account: Not provided
PEP exposure: Yes
PEP associate: Not provided
Sanctions exposure: Yes
Adverse media: Yes
Funding account verified: Not provided
First transaction support obtained: Not provided

Internal compliance checklist

#	Item	Status	Owner	Notes
1	Identity and verification	Completed	Trevor Clein	Identity checked against the government photo identity document and proof of address.

Documents obtained

No documents recorded

Screening

Result: Blocked
Category: Sanctions
List version: ComplyAdvantage list snapshot 2026-04
Checked at: 2026-07-17
Reviewer: Trevor Clein
Notes: Sanctions exposure declared. Funds and onboarding held. Immediate MLRO escalation, no release pending review. Sumsub check could not be completed: Sumsub screening failed: 409.

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

No transactions recorded

Monitoring alerts

No alerts

This client has no monitoring alerts against their current activity.

Periodic review history

No reviews scheduled

Decision history

When	Event	Actor	Detail
17 Jul 2026, 14:20	Onboarding refused	Trevor Clein	Prohibited (EDD Yes, reviewer Trevor Clein) Onboarding refused, prohibited jurisdiction linked to the relationship: Russia. Under the strictest-rule principle this restriction cannot be overridden. Escalated to the MLRO. LionGM does not accept this relationship.

Audit trail

Append-only

When	Action	Actor	Change	Basis
17 Jul 2026, 14:20	Onboarding refused	Trevor Clein	Screening to Prohibited (EDD Yes, reviewer Trevor Clein) Onboarding refused, prohibited jurisdiction linked to the relationship: Russia. Under the strictest-rule principle this restriction cannot be overridden. Escalated to the MLRO. LionGM does not accept this relationship.	Policy 2026-04 2026-04/2026-04
17 Jul 2026, 14:20	Screening completed	Trevor Clein	Draft to Screening (Blocked) Sanctions exposure declared. Funds and onboarding held. Immediate MLRO escalation, no release pending review.	Policy 2026-04 ComplyAdvantage (planned) list snapshot 2026-04
17 Jul 2026, 14:20	Identity verified	Trevor Clein	Verified (manual) Identity and verification step completed. Automated provider (Sumsub) is planned, not live.	Policy 2026-04
17 Jul 2026, 14:19	Draft created	Trevor Clein	Draft Draft individual onboarding file opened for Viktor Petrov.	Policy 2026-04