THE OPERATING MODEL

Know the relationship.
Understand the risk.

Connect identity, ownership, behaviour and evidence. One controlled workspace for AML, CFT, proliferation financing, sanctions and AI-enabled impersonation risk.

01 / KNOW

People & organisations

KYC, KYB and KYE. New relationships and the existing book, with explicit evidence and review dates.

02 / CONNECT

Ownership & behaviour

Legal arrangements, controllers, related parties and transaction evidence in a consistent case model.

03 / DECIDE

Accountable human decisions

Independent approval, restricted investigations and evidence of why each decision was made.

FROM ONBOARDING TO IN-LIFE REVIEW

Connected controls. Clear responsibilities.

Operations & oversight

Relationship onboarding

KYC and KYB for new and existing relationships.

Operations & oversight

Identity & AI impersonation defence

Provider evidence, liveness, injection attacks and manual alternatives.

Operations & oversight

Ownership & legal arrangements

Companies, trusts, funds, nominees and non-equity control.

Operations & oversight

Sanctions, PEPs & adverse media

Versioned data, ownership/control rules and independent match resolution.

Operations & oversight

Ongoing monitoring

Periodic and event-driven reviews with exception tracking.

Operations & oversight

Forensic monitoring

Transaction evidence, scenario controls and restricted investigations.

Restricted control function

Investigations & MLRO

Need-to-know investigations, evidence custody and FIU decisions.

Operations & oversight

Conflicts of interest

Business and personal interests, recusal and independent oversight.

Restricted control function

People & KYE

Lawful workforce checks, role sensitivity and fair review.

Operations & oversight

Mobile verification

Mobile web, SDK and client-app integration assurance.

Operations & oversight

Data providers & APIs

Primary registry data, screening and Atlas integration contracts.

Governance

Board & Company Secretariat

Reserved decisions, committees, statutory records and authority.

First line

People & HR

Organisation charts, fit and proper, training, safeguarding and succession.

First line

Procurement & Outsourcing

Supplier diligence, orders, invoices, criticality and exit planning.

Control function

Legal & Privacy

Contract enforceability, disputes, confidentiality, data rights and transfers.

First line

Technology & Security

Resilience, dependencies, incidents, access and controlled AI.

First line

Change & Transformation

Project initiation, small changes, acceptance and rollback.

Second line

Compliance & Financial Crime

Requirements, testing, advice, AML/CFT/CPF and sanctions investigations.

Third line

Internal Audit

Independent plan, workpapers, findings, retesting and Board assurance.

MOBILE & CLIENT APPLICATIONS

More than a face match.

Design the mobile journey around document authenticity, live capture, presentation-attack detection, camera-injection checks, replay protection and device/session binding. A face match alone does not establish identity or prevent an AI agent from impersonating a customer.

Provider integration records capture privacy assessments, retention, accessible alternatives and independent security validation. Live biometric capture and native app distribution are not enabled in this release.

View customer guidance ↗
PRIMARY DATA & COMPLEX STRUCTURES

Verify the person behind the structure.

Represent companies, partnerships, trusts, foundations, funds, nominees and non-equity control. Record trustees, settlors, protectors, beneficiaries and classes separately. Primary registry evidence must be corroborated; ownership thresholds and sanctions control tests must follow the applicable regime.

Unknown ownership, inaccessible registries and conflicting evidence stay unresolved. This release records relationship links; automated global registry retrieval and recursive ownership calculations require validated integrations.

JURISDICTIONS & EFFECTIVE DATES

Local rules. Explicit applicability.

Isle of Man · Jersey · Guernsey · UK · EU · UAE · Cayman Islands · Bahamas.

Configure the licensed entity, activity, local FIU, PEP treatment, beneficial ownership, sanctions ownership/control rules, retention and reporting deadlines. EU Member States and UAE mainland, DIFC and ADGM require separate profiles. EU Regulation 2024/1624 generally applies from 10 July 2027; future rules must not be treated as current.

Controls support compliance; software does not certify it. Complete local rule mapping, provider contracting and independent operating-effectiveness testing before regulated production use.
EVIDENCE BEFORE PERFORMANCE CLAIMS

Measure speed. Test accuracy.

Benchmark precision, recall, false acceptance/rejection, demographic performance, reviewer workload and p95 latency on the same representative datasets. No comparative performance claim is made against ID-Pal, Arva, Ondato, Thomson Reuters or LexisNexis.

Available: persistent records, server-side permissions, independent approvals and audit history. Not connected: live sanctions/PEP databases, biometric providers, registries, payment streams or FIU submission channels.