INFINITUM CAPITAL LIMITED

Assessment

Legal identity is VERIFIED against an authoritative registry. Commercial identity — what the company actually does — is NOT FOUND. This split is the defining characteristic of the file: the entity's legal existence is well documented, its economic existence is undocumented.

Evidence

Key Findings

• Entity age. Incorporated 31 May 2016; at the report date of 18 August 2026 the company is ten years, two months and eighteen days old. The pre-synthesis brief described it as "nine years old" — that is incorrect and is corrected here. Longevity is mildly reassuring (shell vehicles used for one-off abuse rarely persist a decade with an active status), but is not a substitute for substantive verification.
• Care-of registered office. The C/O prefix confirms the registered office is provided by a third party, Goldwyns London LLP. The nature of Goldwyns London LLP's business was not retrieved and is not asserted here. No.1 Royal Exchange, EC3V 3DG is a City of London address. A professional or agent-provided registered office is lawful and unremarkable in the UK; it does, however, mean the company's actual place of business is unknown to this file.
• Name/activity mismatch is unresolved. The trading style contains "Capital", conventionally associated with investment, fund or lending activity. No evidence retrieved establishes any line of business. The name must not be treated as evidence of regulated activity, nor of any activity at all.
• Identity disambiguation not documented. No evidence indicates that downstream searches (Sections 5–7) were bound to registration number 10206158. See Section 13, Limitations.

Risk Implication

The identification limb of MLR 2017 reg 28(2)(a) (identify the customer) is satisfied for the legal person by authoritative registry data. The understanding-of-business limb (reg 28(2)(a), reg 28(4)(c) constitution and ownership/control, and reg 28(11) purpose and intended nature of the relationship) is not satisfied: nothing in this evidence set describes the company's activity, income model or counterparties. A relationship cannot be risk-rated on a name alone. Obtaining the SIC code, the latest filed accounts and a customer-supplied description of business is the minimum remediation. This gap flows directly into Section 8 (no financial profile) and Section 12 (conditional CDD).

Assessment

Two natural persons are named. One is CONFIRMED in a registry role (director); one is DECLARED in a self-filed register (PSC). No verified beneficial ownership has been established. No ownership percentages, share classes, voting rights or corporate chain were retrieved. There is no evidence of any intermediate corporate layer — but equally no evidence excluding one, because the shareholder register was not retrieved.

Evidence

Not retrieved and material: date of birth (month/year), nationality, country of residence, service address, appointment date, other directorships or PSC positions held by either individual, PSC statement type, shareholder register, whether any corporate PSC exists, and whether the PSC register is marked complete.

Key Findings

1. 1.Control and declared ownership sit with two differently named individuals. Mr Bhatnagar is recorded as a director; Ms Luthra is recorded as a PSC. The evidence does not state that these are the only officers or the only PSCs, and does not state that Mr Bhatnagar is or is not also a shareholder. Any inference of a nominee arrangement, a family arrangement or a separation of legal and beneficial interest would be speculation and is not made here.
2. 2.The 25% threshold is unquantified. Under the UK PSC regime (Companies Act 2006 Part 21A, Sch. 1A), a person is registrable where they hold, directly or indirectly, more than 25% of shares, more than 25% of voting rights, the right to appoint or remove a majority of the board, or otherwise exercise significant influence or control. The evidence records a PSC entry but not which condition was engaged. It is therefore not possible to state from this file whether Ms Luthra holds a majority interest, a bare 25.1% interest, or a control-based (non-equity) interest.
3. 3.Self-declaration is not verification. Companies House does not verify the substance of PSC filings. The entry is properly characterised as a declared beneficial owner. Describing it as verified in any customer file would be inaccurate.
4. 4.No sanctions or PEP screening of the individuals is evidenced. The sanctions ledger entry does not state whether the query covered the two named persons or only the entity. See Sections 3 and 4.

Risk Implication

• FATF Recommendation 24 requires adequate, accurate and up-to-date beneficial-ownership information. EU 5AMLD Article 30 and the UK PSC regime provide the registry mechanism, but registry reliance alone is insufficient.
• MLR 2017 reg 28(4) requires the firm to identify the beneficial owner and take reasonable measures to verify identity so that it is satisfied it knows who the beneficial owner is; reg 28(4)(b) expressly prohibits relying solely on the PSC register.
• Consequence: ownership opacity here is procedural, not structural. There is no evidence of layering, offshore intermediation or nominee directors. But the firm cannot presently evidence that it knows who owns and controls the customer.
• Cross-reference: the absence of verified identity data for these two individuals is what makes the unrun PEP screen in Section 4 more consequential, and it is one of the drivers of the Transparency Risk factor (8/100) in Section 11.

Assessment

Screen status: RUN — no match returned. This is the strongest negative result in the file and the only adverse-domain result not dependent on a general web search engine.

Evidence

Key Findings

• No exact match and no possible name match was returned against OFAC, OFSI or UN lists for the screened string(s).
• Scope limitation — individuals. The evidence does not confirm that BHATNAGAR, Dhruv and Shruti Luthra (Section 2) were screened as separate subjects. Entity-only screening would leave the two natural persons unscreened. This must be confirmed or repeated.
• Scope limitation — list coverage. EU consolidated measures and third-country national lists are not recorded as screened. For a UK-incorporated entity dealing only in the UK this is a modest gap; it widens materially if the relationship involves EU or non-UK counterparties.

Risk Implication

UK financial sanctions obligations arise under the Sanctions and Anti-Money Laundering Act 2018 and are strict-liability in nature; OFSI expects screening at onboarding and on an ongoing basis against the current consolidated list. The nil result supports proceeding, but only within its documented scope. Recommended step: re-run screening with (i) the two named individuals as discrete subjects, (ii) the registered address as a secondary identifier, and (iii) an explicit record of screening date and match threshold, so the screen is auditable. Cross-reference: because beneficial ownership in Section 2 is only DECLARED, a clean sanctions result on the declared PSC does not exclude an undisclosed beneficial owner who is designated — the assurance is only as good as the ownership data it was run against.

Screen status: NOT RUN

Assessment

PEP screening was not performed. The source ledger records No PEP screening provider configured [PEP] → SKIPPED. No PEP, RCA (relative or close associate) or HIO (head of international organisation) determination has been made for the entity or for either named natural person. The composite score in Section 11 was computed without any PEP input and the coverage statement confirms PEP is a domain "NOT reflected in the composite score".

No conclusion may be drawn in either direction. It cannot be stated that the subjects are PEPs; it equally cannot be stated that they are not. Nothing in the retrieved evidence indicates that either individual holds or has held a prominent public function.

What is unestablished

No date of birth, nationality or country of residence was retrieved for either individual (Section 2), which would in any case make a high-precision PEP determination difficult even if a provider had been configured.

Risk Implication

• UK MLR 2017 reg 33(1)(b) requires enhanced due diligence where the customer or beneficial owner is a PEP, a family member or a known close associate; reg 35 sets out the specific PEP obligations, including senior-management approval, establishing source of wealth and source of funds, and enhanced ongoing monitoring.
• MLR 2017 reg 19 and FCA SYSC 6.3 / SYSC 12.1 require adequate systems and controls; FATF Recommendation 12 requires risk-management systems to determine PEP status.
• The firm currently has no mechanism evidenced in this file for making that determination. That is a systems-and-controls gap of regulatory interest independent of this specific customer.
• Do not rely on role-keyword inference. No PEP conclusion may be drawn from the fact that neither individual appears in adverse media (Section 5) — the media screens were nil-return general web searches and are not PEP data sources.

Required remediation

1. 1.Configure and run a commercial PEP/RCA dataset (with domestic UK PEP coverage, which is required under MLR 2017 as amended, subject to the FCA's guidance on the proportionate treatment of domestic PEPs).
2. 2.Screen BHATNAGAR, Dhruv and Shruti Luthra individually, with dates of birth and nationality obtained from the customer to permit disambiguation.
3. 3.Record the provider, dataset version and screening date on file.
4. 4.Do not finalise the onboarding decision until steps 1–3 are complete (see Section 12).

Assessment

Result: NOT FOUND. An adverse-media search ran and returned zero results. No allegation, investigation, charge, conviction, regulatory criticism or reputational incident of any kind was identified concerning INFINITUM CAPITAL LIMITED or the individuals named in Section 2.

The result is genuine but of limited recall assurance, for reasons set out below. It should be recorded as "no adverse media surfaced by the search performed", not as "the entity has no adverse media".

Evidence

Key Findings

• Single-instrument dependency. The adverse-media, regulatory and litigation nil results all originate from the same tool (Google Programmable Search). Three nil returns from one instrument constitute one clean signal replicated, not three independent confirmations. The pre-synthesis brief made this point correctly and it is adopted here; the brief's arithmetic ("four of the five open-source domains") is corrected — Google ran four domains, of which three returned empty and one (financial) returned data.
• No name disambiguation is evidenced. "Infinitum Capital" is a generic, financially-flavoured string that is likely to be shared by unrelated entities across jurisdictions. A nil result on an ambiguous string carries materially less assurance than a nil result on a disambiguated one — and, conversely, any future hit on the bare string will require careful attribution before it is treated as pertaining to company 10206158.
• The OSINT nil line cannot be relied upon. It has no corresponding entry in the source ledger, so it is not possible to state what ran, when, or against what. The pre-synthesis brief's assertion of "zero OSINT footprint" as an established finding is not supported and is corrected here.
• Zero footprint is itself a data point, not a finding. A ten-year-old company with a financial trading style and no discoverable public trace is consistent with a dormant, holding, family-investment or private-mandate vehicle — all lawful and common — and is equally consistent with an entity whose activity is simply not reported. The evidence does not distinguish between these.

Risk Implication

Adverse-media screening is expected as part of the risk assessment under MLR 2017 reg 18/28 and JMLSG guidance. The screen performed is at the low-assurance end of acceptable practice for a customer whose business activity is unknown (Section 1) and whose beneficial ownership is only declared (Section 2). Recommended step: re-run adverse media through a licensed screening database with (i) explicit officer-name queries, (ii) the registration number and registered address as disambiguators, and (iii) a documented lookback period of at least the ten years since incorporation.

Assessment

Result: NOT FOUND — with a material scope defect. A regulatory/enforcement search ran via Google Programmable Search on the assessment date and returned zero results. No regulator's register or enforcement database was queried directly. For an entity whose name signals financial activity, the omission of a direct FCA Financial Services Register check is the most consequential source gap in this section.

Evidence

Key Findings

1. 1.Regulated status is entirely unestablished. It is not known whether INFINITUM CAPITAL LIMITED is FCA-authorised, an appointed representative, exempt, out of scope, or conducting activity that would require authorisation. The name is not evidence of any of these positions.
2. 2.No enforcement action was surfaced by the search that ran. Given the instrument's limitations (Section 5), this supports but does not establish an absence of regulatory history.
3. 3.The strike-off/enforcement trail is clean at registry level. Companies House records the company as active [Source: Companies House], which is inconsistent with a compulsory strike-off process being underway at the point of retrieval. This is a real, if narrow, negative signal.

Risk Implication

If the entity conducts regulated activity without authorisation, that would be an offence under FSMA 2000 s.19 (general prohibition) and would materially change the risk profile and the appropriateness of the relationship. If it is authorised, its permissions and any published enforcement history are directly relevant to risk rating under MLR 2017 reg 18. Neither position can currently be evidenced.

Required step (priority): query the FCA Financial Services Register and FCA Warning List directly for the entity name, the registration number and the director's name, and record the result with the query date. This is a low-cost check that closes a high-salience gap. See Section 12, Required Actions.

Assessment

Result: NOT FOUND. A litigation search ran via Google Programmable Search and returned zero results. Court records were not searched directly. No civil, criminal, insolvency, employment or regulatory proceeding involving INFINITUM CAPITAL LIMITED or the individuals named in Section 2 was identified.

Evidence

Key Findings

• News-source proxy only. The litigation domain was covered by a general web search engine. UK court records (e.g. the Business and Property Courts diary, County Court Judgment register, Insolvency Service notices, The Gazette) were not searched directly. Most first-instance UK civil litigation and the great majority of CCJs never generate press coverage, so a nil web result has limited probative value on the question of whether proceedings exist.
• No insolvency indicator. The active status at Companies House [Source: Companies House] is inconsistent with liquidation or dissolution at the point of retrieval. It does not exclude an outstanding judgment, a winding-up petition not yet reflected, or a charge over assets — the charges register was not retrieved (Section 1).
• Pattern analysis not possible. Repeat litigation, class actions and insolvency are flagged as patterns of interest, but with a zero-item dataset there is nothing to pattern-match. Absence of a pattern here means absence of data, not absence of litigation.

Risk Implication

Undisclosed judgment debt, winding-up activity or fraud litigation would each materially affect creditworthiness and integrity assessment. Recommended step: run a CCJ/judgment search (Registry Trust or equivalent), check The Gazette for insolvency and strike-off notices against company 10206158, and obtain the Companies House charges register. These are proportionate, low-cost checks appropriate to a customer whose economic activity is otherwise undocumented (Sections 1 and 8).

Assessment

Screen status: NOT RUN (no dedicated ESG source)

No ESG data source was consulted. The source ledger contains no ESG, sustainability, modern-slavery, environmental-regulator or data-protection data provider. The only instrument with any potential to surface conduct issues incidentally was the general adverse-media web search (Section 5), which returned nil and carries the recall limitations described there.

ESG & Conduct Risk is not a weighted factor in the supplied scoring model and does not appear in the Section 11 table. Its influence on the composite is nil.

Coverage status by ESG domain

Risk Implication

• No ESG or conduct adverse finding exists in this evidence set, and none may be inferred. Equally, no ESG assurance may be given: the domains above were not examined.
• For a private company of unknown size and activity, dedicated ESG screening may be disproportionate at onboarding. The proportionate position is to record ESG as not assessed with a stated reason, rather than to imply a clean outcome.
• Governance is the one ESG dimension with live compliance relevance here, and it is addressed substantively in Section 2: a self-declared PSC register entry with no verified percentage or nature of control is a governance-transparency weakness that feeds the Transparency Risk factor (8/100) in Section 11.
• Trigger for escalation: if the relationship is intended to involve lending, investment mandates or the handling of third-party funds, ESG and conduct screening should be commissioned before the relationship is material, alongside the FCA Register check in Section 6.

Assessment

Result: effectively NOT FOUND — this is the most significant substantive due-diligence deficiency in the file. No revenue, turnover, asset, liability, funding, investor or profitability information was retrieved. Source of wealth and source of funds are entirely unassessed.

The financial domain search returned a single item: "1 result: 0 adverse, 0 positive, 1 neutral" [Google Programmable Search, FINANCIAL]. The content, publisher, date and subject of that neutral result were not supplied in the evidence. It cannot be summarised, attributed or relied upon, and it is not treated as establishing anything. It should be retrieved and reviewed manually.

Evidence

Red-flag testing against the standard indicators

Risk Implication

• MLR 2017 reg 28(11)(a) requires the firm to obtain information on the purpose and intended nature of the business relationship. Reg 33(1) and reg 35 require source of wealth/funds where EDD applies (including PEP cases — unresolved, Section 4).
• Without any financial baseline, transaction monitoring cannot be calibrated: there is no expected-activity profile against which anomalies could be detected. This directly undermines the ongoing-monitoring obligation in reg 28(11)(b).
• The combination in this file — a financial trading style (Section 1), a care-of registered office (Section 1), a declared-only beneficial owner (Section 2), and zero financial or media footprint (Sections 5 and 8) — does not constitute evidence of misuse. It does mean that every substantive question about the counterparty's economic reality remains open, and that the LOW composite in Section 11 rests on an absence of information rather than on positive assurance.

Required step

Obtain from Companies House the full filing history and the most recent statutory accounts for company 10206158, and obtain from the customer a written description of business activity, expected transaction volumes and values, and documentary source of funds. Retrieve and review the one undescribed neutral financial result.

Assessment

The only jurisdiction evidenced is the United Kingdom (England & Wales), corroborated by the Companies House record and consistent with the user-provided jurisdiction of GB. Operating jurisdictions, customer/counterparty geographies and any offshore presence are unknown — no evidence bearing on cross-border activity was retrieved.

Evidence

Key Findings

• No reference dataset was consulted in this assessment run. The Jurisdiction Risk score of 35/100 is an output of the supplied scoring model; the model's underlying source data and publication dates were not disclosed to this report. No FATF listing status and no TI CPI numeric score are asserted here, because inventing or recalling such figures would breach evidence discipline.
• Jurisdiction Risk is nonetheless the single largest contributor to the composite score — 35 × 6.8% = 2.38 points of the 5.94 raw total, approximately 40% (see Section 11). This is an artefact of every other scored domain returning near-zero, not a signal of elevated country risk.
• The UK's specific typology exposure is relevant qualitatively. UK private companies limited by shares are widely documented in FATF and UK National Risk Assessment literature as a corporate vehicle of choice, and the UK PSC regime is self-declaratory. That systemic context is the reason a declared-only PSC (Section 2) matters here even in a low-risk jurisdiction. No specific typology finding attaches to this entity.
• No offshore indicator was found. The registered address, the incorporation jurisdiction and both named individuals' registry entries are UK-domestic on the face of the evidence. Residence and nationality were not retrieved, so this is a partial picture.

Risk Implication

GB is not, on any conventional assessment, a high-risk third country, and nothing in the evidence suggests exposure to a listed jurisdiction. The residual jurisdictional risk in this file is unknown cross-border exposure, not known high-risk exposure. Because the company's activity is undocumented (Sections 1 and 8), the firm cannot presently exclude the possibility that its counterparties or funds flows involve higher-risk jurisdictions. Required step: obtain from the customer the countries in which it operates, holds bank accounts and transacts, and the nationality/residence of both named individuals; then re-assess.

Assessment

The supplied weighted model returns a composite of 6/100 — LOW band, on PARTIAL coverage. The arithmetic reproduces exactly. The band is accepted as the model output; the confidence in it is LOW, and the score must be read as "no adverse findings surfaced across the domains that ran", not as "verified low risk".

Scoring table (applied/renormalised weights, verbatim from the supplied model)

Applied weights as supplied sum to 99.9% before rounding; the composite is reported by the model as 6/100.

Calculation

Composite Score = Σ(Factor Score × Applied Weight)

• Sanctions & Watchlists: 3 × 0.341 = 1.023
• Adverse Media: 4 × 0.227 = 0.908
• Regulatory & Enforcement: 4 × 0.204 = 0.816
• Politically Exposed Persons: not scored — screen did not run; no weight applied
• Litigation: 4 × 0.114 = 0.456
• Jurisdiction Risk: 35 × 0.068 = 2.380
• Transparency Risk: 8 × 0.045 = 0.360

Σ = 1.023 + 0.908 + 0.816 + 0.456 + 2.380 + 0.360 = 5.943 → reported composite 6/100 (LOW band).

What actually drives the score

1. 1.Jurisdiction Risk alone accounts for ~40% of the composite (2.380 of 5.943), despite carrying the second-smallest weight, because its raw score (35) is roughly nine times that of any other scored factor. This is a structural artefact of a file in which no adverse content was returned anywhere.
2. 2.Sanctions carries the dominant weight (34.1%) and scored 3 — the most reliable single input in the file, being the only adverse-domain screen not routed through a general web search engine.
3. 3.The three lowest-assurance inputs — Adverse Media, Regulatory and Litigation — collectively carry 54.5% of the applied weight and were all produced by the same instrument. Their combined contribution (2.180) is only marginally larger than jurisdiction risk alone, but their reliability is the weakest part of the model's foundation.
4. 4.PEP contributes nothing. Because weights were renormalised across the domains that ran, the absence of PEP data does not depress the score — it removes the possibility of the score being raised by a PEP finding. A composite computed on this basis cannot be represented as complete.

Band consistency and confidence

• Band: LOW — consistent with the arithmetic and reproduced faithfully.
• Confidence: LOW — driven by (i) the unrun PEP screen, (ii) the unqueried FCA Register, (iii) zero financial data, (iv) beneficial ownership that is declared rather than verified, and (v) the single-instrument, non-disambiguated basis of three of the four nil results.
• A LOW score at LOW confidence is not equivalent to a LOW score at HIGH confidence and must not be recorded in the customer file as though it were. The composite measures what was found; the confidence rating measures whether the search was capable of finding it.

Recommendation

Standard CDD — CONDITIONAL. Onboarding decision to be deferred pending three named checks.

The supplied model recommends Standard CDD, EDD: NO, monitoring ANNUAL. That recommendation is accepted as the destination but not as the current status. The correct present status is:

DECISION PENDING — ADDITIONAL INFORMATION REQUIRED

Enhanced Due Diligence is not triggered by anything in the evidence: there is no high-risk third country (Section 9), no complex or opaque structure evidenced (Section 2), no sanctions nexus (Section 3), no adverse media, regulatory or litigation finding (Sections 5–7), and no PEP finding — because no PEP screen was run (Section 4). Rejection or termination is NOT recommended; the evidence contains no adverse finding of any kind, and information gaps alone do not justify refusal.

Rationale

Outstanding information gaps

1. 1.PEP/RCA/HIO status of BHATNAGAR, Dhruv and Shruti Luthra — not screened.
2. 2.Independent verification of beneficial ownership, including percentage held and the PSC condition engaged (the >25% shares / >25% voting rights / board-appointment / significant-influence limbs).
3. 3.Date of birth, nationality and country of residence for both named individuals.
4. 4.Nature of business, SIC code and a customer-supplied description of activity.
5. 5.Latest filed statutory accounts and full Companies House filing history, including accounts type (dormant / micro / small / full).
6. 6.FCA Financial Services Register and FCA Warning List status.
7. 7.Companies House charges register; CCJ/judgment search; Gazette insolvency notices.
8. 8.Content of the single undescribed neutral financial search result.
9. 9.Actual place of business (the registered office is a care-of address at Goldwyns London LLP).
10. 10.Operating jurisdictions, banking arrangements and expected counterparty geographies.

Required Actions

1. 1.Run PEP screening (commercial provider, domestic and foreign PEP coverage) on the entity and on both named individuals. Record provider, dataset version and date. — Owner: Screening / Analyst. Priority: immediate, blocking.
2. 2.Query the FCA Financial Services Register and FCA Warning List directly for INFINITUM CAPITAL LIMITED, company number 10206158, and BHATNAGAR, Dhruv. Record the query date and result. — Owner: Analyst. Priority: immediate, blocking.
3. 3.Obtain and review the Companies House full filing history, latest accounts, PSC statement detail, officer list and charges register for 10206158. — Owner: Analyst. Priority: immediate, blocking.
4. 4.Re-screen sanctions with the two individuals as discrete subjects, documenting screening date and match threshold. — Owner: Screening.
5. 5.Re-run adverse media and litigation through a licensed screening database, disambiguated by registration number, registered address and officer names, over a lookback covering 31 May 2016 to date. — Owner: Analyst.
6. 6.Collect from the customer: written description of business and purpose of the relationship; expected transaction volumes/values; source of funds; operating jurisdictions; verified ID and proof of address for the director and the declared PSC; confirmation of the actual trading address. — Owner: Relationship owner.
7. 7.Do not record the file as "clear" or "screened" until items 1–3 are complete. The current LOW composite is a partial-coverage output (Section 11).

Monitoring and review

Trigger events for immediate review

• Any PEP, RCA or HIO match on either named individual.
• Any sanctions match, including a possible/partial name match requiring adjudication.
• Appearance on the FCA Warning List, or evidence of regulated activity without authorisation.
• Change of director, PSC, registered office or company name at Companies House.
• Filing of a first set of accounts materially inconsistent with the stated business, or a change from dormant to trading status.
• Any winding-up petition, CCJ, charge registration or Gazette notice.
• Transaction activity inconsistent with the (currently absent) expected-activity profile — noting that until Action 6 is complete, no monitoring baseline exists.

Every URL behind a finding in this report. “Read in full” means the page itself was retrieved and classified on its whole text rather than on a search snippet; those carry a SHA-256 hash of exactly what was read, so the evidence can be shown to be unaltered later.

Complete source ledger

Date of assessment: 18 August 2026. Coverage status: PARTIAL.

Methodology

1. 1.Evidence segregation. Registry and UBO data (authoritative) were treated separately from third-party retrieved content (untrusted). Verification labels — CONFIRMED / DECLARED / VERIFIED / NOT FOUND / SKIPPED / UNVERIFIED — were applied per item and are used consistently throughout.
2. 2.Injection review. The UNTRUSTEDRETRIEVEDCONTENT block was reviewed for embedded directives, requests or attempts to influence scoring. None were present. The block contained only nil-result statements and one numeric tally. The pre-synthesis brief's integrity note is therefore verified, not merely adopted.
3. 3.Pre-synthesis brief treated as an input to test, not as fact. Three corrections were made: - The brief states the company is "nine years old". It was incorporated 2016-05-31; at the report date it is ten years and approximately three months old. Corrected in Sections 1 and the executive summary. - The brief states "four of the five open-source domains were searched by one instrument … and returned nothing". Per the ledger, Google Programmable Search ran four domains, of which three returned empty and one (financial) returned data. Corrected in Section 5. The brief's underlying analytical point — correlated single-instrument nil results — is sound and is adopted. - The brief asserts "zero OSINT footprint" as an established finding. No OSINT source appears in the source ledger, so this cannot be substantiated. Corrected in Section 5 and recorded above. - The brief's characterisation of Goldwyns London LLP as "a third-party professional firm" goes marginally beyond the evidence: the C/O prefix establishes a third-party address, but the nature of that firm's business was not retrieved. Narrowed accordingly in Section 1.
4. 4.Scoring. All factor scores and applied (renormalised) weights in Section 11 were taken verbatim from the supplied risk model. The arithmetic was reproduced and reconciles to 5.943 → 6. No factor was added, removed or re-weighted. The PEP row is carried as UNDETERMINED with no weight.
5. 5.Absence handling. No NOT FOUND result was converted into a positive assurance. No SKIPPED source was treated as a clean outcome. No adverse assertion appears in this report, because none exists in the evidence.

Limitations

• PEP screening did not run and is excluded from the composite. This is the single largest coverage gap (Section 4).
• No regulator register was queried directly. Authorised/unauthorised status is unknown for an entity with a financial trading style (Section 6).
• Three of the four nil adverse-content results derive from one search instrument, with no documented disambiguation to company number 10206158, the registered address or the officer names. "Infinitum Capital" is a generic string; recall assurance is correspondingly low (Section 5).
• No financial data of any kind was obtained. Source of wealth and source of funds are unassessed; no expected-activity baseline exists for monitoring (Section 8).
• Beneficial ownership is declared, not verified, with no percentage or control basis retrieved (Section 2).
• One retrieved financial result was returned without content, and therefore cannot be summarised or relied upon (Section 8).
• No jurisdiction reference datasets (FATF, EU, TI CPI) were retrieved; the Jurisdiction Risk score of 35 is a model output whose underlying data was not disclosed (Section 9).
• No ESG data source was consulted (Section 10).
• No identity disambiguation is documented anywhere in the search chain, meaning both the nil results and any future hits will require attribution work before use.

Legal and regulatory framework referenced

UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 — regs 18, 19, 27, 28 (incl. 28(2), 28(4), 28(11)), 33, 35; FCA SYSC 6.3 and SYSC 12.1; FSMA 2000 s.19; Sanctions and Anti-Money Laundering Act 2018; Companies Act 2006 Part 21A and Sch. 1A (PSC regime); UK Modern Slavery Act 2015 s.54; FATF Recommendations 12 (PEPs) and 24 (beneficial ownership of legal persons); EU 5AMLD Article 30; EU 6AMLD.

Confidence

Overall confidence: LOW.

The principal reasons are: (i) a mandatory screening domain (PEP) did not run at all; (ii) the majority of the applied weight in the scoring model (54.5% across adverse media, regulatory and litigation) rests on nil returns from a single, non-disambiguated general web search instrument; (iii) beneficial ownership is self-declared and unverified; (iv) the entity's business activity and financial position are entirely undocumented; and (v) no direct regulator-register check was performed despite a trading style that implies financial activity.

Confidence is HIGH for one narrow proposition only: the legal existence, jurisdiction, incorporation date, company type and current active status of INFINITUM CAPITAL LIMITED, company number 10206158, as recorded by Companies House. Confidence is MEDIUM for the sanctions nil result, within its documented scope. Confidence is LOW or UNDETERMINED for every other proposition in this report.