INFINITUM CAPITAL LIMITED

Assessment

Core identity is VERIFIED against an authoritative registry. Business activity, filing currency and regulatory permissions are NOT ESTABLISHED — these fields were not returned by the query and are material gaps for an entity trading under the word "Capital".

Evidence

Key Findings

• Corporate age: just over ten years as at the report date (18 August 2026), incorporated 2016-05-31. This is not a newly formed shell; longevity is a mildly mitigating identity factor.
• Care-of registered office: the address is prefixed "C/O Goldwyns London Llp" at No.1 Royal Exchange, EC3V 3DG. This indicates a professional-services or accountancy service address. This is lawful and extremely common, but it means no operating premises is evidenced anywhere in this file. The firm cannot state where the company actually trades.
• Business activity unknown: the absence of a SIC code is the single most consequential registration gap. The word "Capital" in the name creates a reasonable inference of investment or fund activity, which would engage FSMA authorisation questions — but an inference is not evidence and must not be recorded as a finding.

Risk Implication

Identity risk is low; activity-and-permissions risk is unresolved. Under MLR 2017 reg. 28(3) the firm must understand the nature of the customer's business. That understanding cannot be constructed from the present evidence. Two actions close the gap definitively: (a) retrieve the full Companies House filing record including SIC code and latest accounts; (b) query the FCA Financial Services Register on company number 10206158. Note the connection to Section 8 — the absence of a business description and the absence of financial data compound one another.

Assessment

Two natural persons are named. One is CONFIRMED by an authoritative registry as an officer; the other is DECLARED to the PSC register by the company itself and is not independently verified. No corporate chain, no ownership percentage and no relationship between the two individuals is evidenced. Ultimate beneficial ownership is therefore not confirmed.

Named Persons

The 25% Threshold

Under the UK PSC regime (Companies Act 2006 Part 21A, as amended by the Small Business, Enterprise and Employment Act 2015) a person must be entered on the PSC register where they, directly or indirectly, hold more than 25% of the shares, hold more than 25% of the voting rights, hold the right to appoint or remove a majority of the board, or otherwise exercise significant influence or control. This aligns with the beneficial-ownership definition in MLR 2017 reg. 5 and FATF Recommendation 24.

The specific PSC condition and percentage band applicable to Shruti Luthra was not retrieved. This matters because the register does not distinguish, on the face of this evidence, between a >25% shareholder, a >50% shareholder, and a person registered solely under the "significant influence or control" limb. Those are materially different control positions.

Key Findings

• Director ≠ PSC. Dhruv Bhatnagar appears as a director but not as a PSC. Shruti Luthra appears as a PSC but not, on this evidence, as an officer. No family, professional or contractual relationship between them is evidenced. This is entirely normal in a privately held company but leaves the control map incomplete.
• No corporate layers evidenced, and none excluded. The evidence discloses no intermediate holding company. It also does not affirmatively confirm that none exists — the PSC entry is for a natural person, which is a positive indicator, but the full share register was not obtained.
• No identity attributes retrieved for either individual: no date of birth, nationality, country of residence, correspondence address or Companies House personal appointment ID. Without these, neither person can be reliably distinguished from same-name individuals in downstream screening.

Risk Implication

MLR 2017 reg. 28(4)(a)–(c) requires the firm to identify the beneficial owner and take reasonable measures to verify their identity so that it is satisfied it knows who the beneficial owner is. Reg. 28(4A) and the JMLSG guidance are explicit that reliance on the PSC register alone does not discharge this obligation. The DECLARED status of Shruti Luthra must therefore be converted to verified through independent documentary evidence before onboarding is completed.

The absence of DOB and nationality directly degrades Section 3 (sanctions match confidence cannot be assessed against individuals) and Section 4 (PEP screening, once run, will produce unresolvable name collisions without identity attributes). This is a single gap with three downstream consequences.

Assessment

Screen status: RAN — genuinely no findings returned. This is a real negative result and is the strongest clean signal in the file. It is not an absence of data.

Evidence

Key Findings

• The distinction that matters here: this is an exact-match screen returning zero hits, not a possible-match requiring adjudication. There is no name to disambiguate and no designation to assess.
• The screening date is not recorded. For audit purposes the firm must be able to state the date on which the lists were interrogated. The report date is 18 August 2026, but the evidence does not confirm the screen ran on that date. This should be captured before the file is closed.
• Scope limitation: three list sets were screened. The EU consolidated list and other national regimes are not stated to have been covered. Where the counterparty has or may acquire EU exposure, that gap is material.
• Individual-level screening cannot be quality-assured. The evidence does not confirm whether Dhruv Bhatnagar and Shruti Luthra were screened as individuals, nor with what identity attributes. Given Section 2 records no DOB or nationality for either person, any individual-level screening that did occur would have been name-only and therefore of limited reliability.

Risk Implication

The empty result supports the low Sanctions & Watchlists factor score of 3/100, which carries the heaviest applied weight in the model (34.1%) and is the principal reason the composite sits in the Medium-Low band (Section 11).

Under UK sanctions law the obligation is strict-liability and continuous, not point-in-time. Two follow-ups are required: (1) confirm and record the screening date and the individual-level scope; (2) place the entity and both named persons under ongoing sanctions monitoring rather than relying on this single screen. Note also that OFSI's ownership-and-control test (50%+ or control) means that the unresolved ownership picture in Section 2 constrains how far this clean result can be extended to the entity's ultimate owners.

Assessment

Screen status: NOT RUN

No PEP screening was performed on this entity or on either named individual. The source ledger records: "No PEP screening provider configured [PEP] → SKIPPED". The coverage statement confirms PEP is a "risk domain NOT reflected in the composite score".

This report makes no determination as to whether Dhruv Bhatnagar, Shruti Luthra, or any associated person is a PEP, a relative or close associate (RCA) of a PEP, or a head of international organisation (HIO). No such determination can be made from the supplied evidence.

What Cannot Be Stated

No inference of PEP status has been drawn from job titles, names, or open-source keyword matching. Role-keyword inference is not a substitute for a screening provider and would not be defensible to a regulator.

Regulatory Position

• UK MLR 2017 reg. 33(1)(b) requires enhanced due diligence in any business relationship with a PEP, family member or known close associate.
• UK MLR 2017 reg. 35 requires firms to have appropriate risk-management systems and procedures to determine whether a customer or beneficial owner is a PEP. A firm with no configured PEP data source does not have such a system in place for this file.
• FATF Recommendation 12 and FCA SYSC 12.1 carry equivalent expectations.
• FCA FG17/6 confirms the determination must be made at onboarding and maintained thereafter.

Risk Implication

This is the most significant control failure in the file. Its effect is threefold:

1. 1.The composite score of 37/100 is incomplete by construction. The remaining six factor weights were renormalised across the domains that ran, meaning the model redistributed PEP's weight to other factors rather than penalising the gap. A reader could mistake 37/100 for a complete assessment; it is not.
2. 2.The "EDD required: NO" output cannot be relied upon. If either individual is a PEP, EDD becomes mandatory under reg. 33 regardless of every other finding in this report.
3. 3.The gap compounds the Section 2 weakness. Screening Shruti Luthra will be name-only, because no DOB, nationality or country of residence was retrieved. Both surnames present in this file are common; false-positive volume should be anticipated and adjudicated with identity attributes obtained from the client, not from open sources.

Required next step: configure a PEP/RCA data provider and screen both named individuals before any onboarding decision is recorded. This is stated as Immediate Action in the Executive Summary and as Required Action 1 in Section 12.

Assessment

Ten open-source results were returned via Google Programmable Search. Two were classified HIGH-severity adverse. On inspection, neither concerns INFINITUM CAPITAL LIMITED (10206158). One relates to a different legal person in a different jurisdiction; the other predates the subject's incorporation by nearly two decades. No reliable adverse media concerning the subject entity was identified.

Result Profile

Adverse Item Analysis

Item 1 — FinStat.sk company profile

• Source / URL: https://finstat.sk/56739036 (snippet dated Jan 29, 2025)
• Subject of the item: INFINITUM CAPITAL s. r. o. — a Slovak legal form (spoločnosť s ručením obmedzeným), i.e. a different legal person, in a different jurisdiction, on a different registry, bearing an identifier (56739036) unrelated to UK company 10206158.
• Allegation type: None. The snippet is a financial-data listing page. The words "FinStat ANTI MONEY LAUNDERING" that appear in the snippet are a FinStat site-navigation label for a commercial product, not an allegation, investigation, charge or finding against anyone.
• Outcome: Not applicable — no allegation exists.
• Classification: NOT FOUND (false positive). Entity resolution fails on name, legal form, jurisdiction and registry identifier.

Item 2 — NASAA policy paper

• Source / URL: https://www.nasaa.org/911/securities-frauds-on-the-internet-and-current-issues-concerning-online-trading/
• Date: 1999-03-23
• What it reports: a North American Securities Administrators Association paper on internet securities fraud, which NASAA states describes an SEC enforcement action, following investigation by the Pennsylvania Securities Commission, concerning an entity abbreviated "AIF". This is reported as NASAA's account; it is attributed, not asserted as established fact by this report.
• Entity resolution: the item names "AIF", not Infinitum Capital. It was published 17 years before the subject was incorporated on 2016-05-31 and is chronologically incapable of concerning it.
• Classification: NOT FOUND (false positive).

AML/CTF Relevance

None established. Neither item constitutes an allegation against the subject. Applying the required distinction — allegation ≠ investigation ≠ charge ≠ conviction — item 1 contains no allegation at all, and item 2 refers to a US regulatory enforcement action against a differently-named entity in 1999.

Evaluation of the Pre-Synthesis Brief

The pre-synthesis brief reached the same entity-resolution conclusions on both items, and its reasoning is supported by the evidence. Two qualifications:

• The brief is truncated mid-sentence ("compoundsemiconductor.") and its analysis of the litigation items is therefore incomplete. Section 7 completes it independently.
• The brief asserts that the composite score "is largely a measurement of how noisy the name 'Infinitum Capital' is." That characterisation is directionally supported for the Adverse Media and Litigation factors. It does not explain the Regulatory & Enforcement factor score of 71/100, which arose from a domain returning zero adverse items and is a separate, unexplained issue (Section 11).

Risk Implication

The Adverse Media factor is scored 62/100 with 22.7% applied weight, contributing 14.07 points — roughly 38% of the entire composite — on the strength of two items that resolve to other parties. Compliance action:

1. 1.Do not record either item as an adverse finding against INFINITUM CAPITAL LIMITED, Dhruv Bhatnagar or Shruti Luthra. Doing so would create a materially inaccurate customer record.
2. 2.Record both as adjudicated false positives with reasons, so that recurrence at the next annual review is dispositioned in minutes rather than re-escalated.
3. 3.Note the residual limitation: a generic web search is not an adverse-media database. Absence of hits on Google Programmable Search is weak evidence of absence. If the relationship is material, a dedicated adverse-media/negative-news provider should be run before reliance is placed on this domain.

Assessment

The regulatory search returned ten results with zero adverse items at any severity level. No regulator, no enforcement matter, no penalty and no sanction concerning INFINITUM CAPITAL LIMITED was identified. However, no regulator register was directly queried — the domain was covered only by generic web search, and the model nonetheless assigned this factor a score of 71/100.

Evidence

Key Findings

• No enforcement history was found — but no register was checked. These are different statements and must not be merged. Under the evidence-discipline rule, "not found on a generic web search" cannot be converted into "no regulatory history".
• The FCA Register gap is the material one. For an entity named "...Capital" with no retrieved SIC code, the firm cannot currently state whether the company is authorised, an appointed representative, an exempt person, or conducting no regulated activity at all. Carrying on a regulated activity without authorisation is an offence under FSMA 2000 s.19; the possibility is neither evidenced nor excluded here.
• Scoring anomaly. The Regulatory & Enforcement factor is scored 71/100 — the highest of the seven factors — while its underlying evidence records 0 adverse, 0 critical, 0 high, 0 medium, 0 low. The model's derivation is not disclosed and cannot be reproduced from the supplied evidence. This is flagged as a model-validation issue in Section 11 and expressly not as an adverse finding against the subject.

Risk Implication

This factor contributes 14.48 points to the 37-point composite — the single largest contribution — without a supporting adverse item. Two consequences:

1. 1.The composite should be read as an upper bound on entity-specific risk. If this factor is a scoring artefact, the entity's evidenced risk is lower than 37/100.
2. 2.That does not make the relationship lower-risk in practice, because the regulatory-permissions question (Section 1) remains open and is a genuine, unclosed gap. The correct posture is: no evidenced enforcement history, unresolved authorisation status.

Assessment

Three MEDIUM-severity litigation items were returned. None evidences legal proceedings involving INFINITUM CAPITAL LIMITED. Two arise from a sentence-boundary text artefact; the third is a funding announcement whose adverse classification derives from an unrelated headline on the same page. No court records were searched directly.

Result Profile

Item-by-Item Analysis

Key Findings

• No party-to-proceedings finding exists. In none of the three items is INFINITUM CAPITAL LIMITED named as claimant, defendant, respondent or appellant.
• No pattern indicators present. There is no evidence of repeat litigation, class action, group action, or insolvency/winding-up proceedings. The registry status is active, which is inconsistent with insolvency but does not by itself exclude pending proceedings.
• Item 1 is an intelligence lead, not an adverse finding. If the "Infinitum Capital" named as an Ayar Labs Series C investor is the subject, that would establish venture-capital investment activity — directly relevant to the business-activity gap in Section 1 and the source-of-funds gap in Section 8. This should be put to the client as an open question, framed neutrally. It must not be recorded as litigation exposure.

Coverage Limitation

Court records were NOT searched directly.

No query was run against: the English & Welsh courts (including the Business and Property Courts), the Insolvency Service register, the London Gazette (winding-up petitions, notices), the Judiciary/BAILII/Find Case Law judgment databases, or any County Court Judgment register. The litigation domain rests entirely on Google Programmable Search.

Risk Implication

The Litigation factor is scored 42/100 at 11.4% applied weight, contributing 4.79 points. That contribution derives wholly from three items that fail entity resolution.

More importantly, an empty web-search result is not a clean litigation record. Most UK first-instance civil proceedings, County Court Judgments and insolvency petitions do not surface in general web search. If the relationship is financially material, a direct check of the London Gazette and the Insolvency Service register should be run — these are low-cost and would convert a weak negative into a defensible one.

Assessment

Screen status: NOT RUN

No dedicated ESG, sustainability, human-rights, modern-slavery or data-protection data source was consulted. No ESG rating provider, no NGO or campaign database, no ICO enforcement register and no regulatory sustainability disclosure was queried. Any ESG signal in this file would have arisen only incidentally through the four generic Google Programmable Search domains; none did.

Coverage Table

Governance Observations (from registry evidence, not an ESG screen)

These are drawn from Sections 1 and 2 and are the only conduct-relevant observations the evidence supports:

• Single confirmed director. Only one officer, Dhruv Bhatnagar, is evidenced. A sole-director structure concentrates decision-making and removes internal challenge. This is lawful and common in private companies; it is a governance characteristic, not a finding of misconduct.
• Beneficial ownership declared but unverified. Reliance on a self-declared PSC filing without independent verification is a transparency weakness. It is the principal driver available to the Transparency Risk factor.
• Care-of registered office. Reduces the public visibility of the operating footprint.

Statutory Reference Points

• UK Modern Slavery Act 2015 s.54 — a s.54 statement obligation arises only above a £36m turnover threshold. Turnover is unknown (Section 8), so it cannot be determined whether the obligation applies, and no statement was searched for.
• CSRD / TCFD — applicability depends on size and listing status, neither of which is evidenced.
• UN Global Compact — no participation status was checked.

Risk Implication

ESG & Conduct Risk is not one of the seven weighted factors in this model. It contributes nothing directly to the composite score of 37/100 and does not appear in the Section 11 table. Its influence reaches the score only indirectly, through the Transparency Risk factor (scored 8/100).

The practical implication: no ESG conclusion — positive or negative — may be drawn from this report. If the counterparty's sector, contract value or public profile makes ESG exposure relevant, a dedicated screen must be commissioned separately. Recording "no ESG issues identified" on the basis of this file would convert an unrun screen into a clean result and would be indefensible.

Assessment

No financial data of any kind was obtained. The financial search returned ten results (0 adverse, 3 positive, 7 neutral) but no figures were carried into the evidence set, and the Companies House query returned no accounts data. Source of funds and source of wealth are entirely unassessed. This is a due-diligence deficiency, explicitly flagged.

Evidence

The Single Financial Lead

The Ayar Labs Series C article (https://compoundsemiconductor.net/article/114667/AyarLabsRaises130MinSeriesC_Funding, Apr 27, 2022) names "Infinitum Capital" among participants in a US$130m round. Two constraints:

1. 1.The US$130m figure is the size of the Ayar Labs round, not a sum attributable to Infinitum Capital. No participation amount is stated. Presenting it as a figure relating to the subject would be a fabrication.
2. 2.It is not established that the named investor is the subject entity. The item is an UNVERIFIED_LEAD under the evidence hierarchy and is excluded from scoring.

It is nevertheless the only signal in the file as to what this company might do, which underlines how thin the financial picture is.

Red-Flag Screen

No red flag is asserted. Equally, none has been excluded, and the report must not imply otherwise.

Risk Implication

Under MLR 2017 reg. 28(11)(a) the firm must obtain information on the purpose and intended nature of the business relationship, and under reg. 28(12) conduct ongoing monitoring including scrutiny of transactions against known source of funds. Neither is possible on this file.

This gap interlocks with two others: the missing SIC code (Section 1) means the firm does not know the business, and the DECLARED-only PSC with no percentage band (Section 2) means it does not know who ultimately benefits. Financial statements from Companies House would partially close all three simultaneously and should be the first document requested.

Assessment

The entity's country of incorporation is verified as the United Kingdom by an authoritative registry, resolving the "user-provided" jurisdiction flag. The UK is a FATF member and appears on no FATF or EU high-risk list. Operating jurisdictions beyond the registered office are unknown, and no reference dataset (FATF lists, TI CPI) was independently consulted in this assessment.

Evidence

Key Findings

• The Slovak connection is a name collision, not a jurisdictional exposure. INFINITUM CAPITAL s. r. o. (https://finstat.sk/56739036) is a separate Slovak legal person (Section 5). Slovakia must not be recorded as an operating jurisdiction of the subject.
• The US references are likewise not jurisdictional exposures of the subject. The NASAA 1999 item and the Ayar Labs funding item do not establish US operations by INFINITUM CAPITAL LIMITED. The Ayar Labs item remains an unresolved lead only (Sections 7 and 8).
• City of London registered address. A No.1 Royal Exchange, EC3V 3DG address held care-of a professional firm is unremarkable and lawful, but is a service address and provides no evidence of the entity's actual geographic footprint.
• No CPI figure is cited in this report because none was supplied. Quoting a specific CPI score without a sourced dataset would be a fabrication.

Risk Implication

The Jurisdiction Risk factor is scored 35/100 at 6.8% applied weight, contributing 2.38 points — the second-smallest contribution. That is consistent with a FATF-member, non-listed jurisdiction with a strong AML framework.

The residual risk is not the jurisdiction of incorporation but the unknown jurisdiction of operation. A UK-incorporated company may transact predominantly with high-risk countries; nothing in this file addresses that. Because Section 8 establishes that no financial or transactional data exists, geographic exposure will only become assessable through client-provided information on counterparties, banking arrangements and markets served. This should form part of the Section 12 information request.

Composite Result

Weighted Factor Table

Scores and applied (renormalised) weights are taken verbatim from the supplied RISK SCORE block.

Calculation

Composite Score = Σ(Factor Score × Applied Weight)

``` Sanctions & Watchlists : 3 × 0.341 = 1.023 Adverse Media : 62 × 0.227 = 14.074 Regulatory & Enforcement : 71 × 0.204 = 14.484 Politically Exposed Persons : UNDETERMINED — screen did not run, no contribution Litigation : 42 × 0.114 = 4.788 Jurisdiction Risk : 35 × 0.068 = 2.380 Transparency Risk : 8 × 0.045 = 0.360

Composite = 37.109 → 37 / 100 (Medium-Low) ```

Applied weights sum to 100.0% (34.1 + 22.7 + 20.4 + 11.4 + 6.8 + 4.5 = 99.9%, rounding). The arithmetic reproduces the supplied composite exactly.

What Actually Drives the Score

28.56 of the 37.11 points — 77% of the composite — comes from Adverse Media and Regulatory & Enforcement. On examination:

• The Adverse Media contribution (14.07) rests entirely on two false positives.
• The Regulatory & Enforcement contribution (14.48) rests on a domain that returned zero adverse items.

Analytical conclusion: the composite of 37/100 substantially overstates the entity-specific evidenced risk. Read strictly against the evidence, the only substantiated risk-relevant facts are (a) a genuinely clean sanctions screen, (b) an active ten-year-old UK registry record with a confirmed director, and (c) a set of information gaps.

However, the score must not simply be revised downward, for three reasons:

1. 1.The scoring model is supplied and has not been validated by this assessment; overriding it unilaterally would be as unsound as accepting it uncritically.
2. 2.The PEP domain is excluded. Weights were renormalised across the domains that ran, which means the model redistributed PEP's weight rather than penalising its absence. The composite therefore reflects no uncertainty premium for a mandatory unrun screen.
3. 3.Genuine unclosed gaps exist — FCA authorisation status, SIC code, accounts, PSC verification, court records — each of which could move the assessment upward once resolved.

Net position: 37/100 Medium-Low is retained as the recorded score. It should be understood as an upper bound on evidenced risk combined with an under-statement of residual uncertainty — the two effects run in opposite directions and do not cancel. Confidence is MEDIUM rather than HIGH for precisely this reason.

Recommended Model Feedback

Two issues should be raised with the model owner: (1) the Regulatory & Enforcement factor scoring 71/100 on a nil-adverse dataset; (2) weight renormalisation across unrun domains, which allows a PARTIAL-coverage file to produce a score numerically indistinguishable from a complete one.

Recommendation

STANDARD CDD — CONDITIONAL. Do not complete onboarding until Required Actions 1–4 are closed.

Rationale

The evidence supports Standard CDD:

• Sanctions screening against OFAC, OFSI and UN ran and returned nothing (Section 3) — the single strongest and heaviest-weighted signal.
• Registry identity is VERIFIED: active status, ten years of corporate existence, named natural-person director CONFIRMED (Sections 1–2).
• Every adverse open-source item fails entity resolution (Sections 5 and 7). None constitutes an allegation, investigation, charge or conviction concerning this entity or these individuals.
• Jurisdiction is a FATF member, not on any high-risk list (Section 9).

The conditionality is driven by:

• PEP screening did not run — a mandatory MLR 2017 reg. 35 determination is absent (Section 4).
• FCA authorisation status was never checked on an entity named "Capital" with no retrieved SIC code (Sections 1 and 6).
• Beneficial ownership is DECLARED, not verified, with no percentage band and no corporate chain (Section 2).
• No financial data exists at all, so source of funds and source of wealth are unassessed (Section 8).

Outstanding Information Gaps

Required Actions

1. 1.Execute PEP/RCA screening on Dhruv Bhatnagar and Shruti Luthra through a configured provider. Record the provider, date and adjudication of every hit. Blocking — no onboarding decision before completion.
2. 2.Query the FCA Financial Services Register for INFINITUM CAPITAL LIMITED / company number 10206158 and record the result (authorised / AR / EMI-PI / exempt / not authorised). Blocking.
3. 3.Retrieve the full Companies House filing record: SIC code, latest filed accounts, confirmation statement, share capital, registered charges, and the PSC statement including the nature-of-control band. Blocking.
4. 4.Verify the declared PSC to documentary standard under MLR 2017 reg. 28(4) — government-issued photographic ID plus independent address evidence for Shruti Luthra, and equivalent for Dhruv Bhatnagar. Capture DOB, nationality and country of residence. Blocking.
5. 5.Obtain from the client a written description of business activity, operating jurisdictions, principal counterparties and banking arrangements, and a trading address distinct from the care-of registered office.
6. 6.Record the five open-source items as adjudicated false positives with written reasons, so recurrence at annual review is dispositioned without re-escalation.
7. 7.Run direct insolvency and gazette checks (London Gazette, Insolvency Service register) to convert the weak litigation negative into a defensible one.
8. 8.Record the sanctions screening date and individual-level scope, currently absent from the file, and enrol the entity and both individuals in ongoing sanctions monitoring.

Trigger Events for Immediate Review

• Any PEP, sanctions or watchlist match arising at any time on the entity or either named individual.
• Confirmation that the entity conducts regulated activity without FCA authorisation, or any change in FCA authorisation status.
• Any change of director, PSC, registered office, or company name at Companies House.
• Any accounts filing showing negative net assets, or any overdue accounts / confirmation statement / strike-off proposal.
• Appointment of an insolvency practitioner, filing of a winding-up petition, or a London Gazette notice.
• Any credible adverse media item that does resolve to company number 10206158 or to a named individual with matching identity attributes.
• Transactional activity inconsistent with the business description obtained under Required Action 5.

Explicit Caution

The two HIGH-severity adverse-media items and the three MEDIUM litigation items must not be carried into the customer record as adverse findings. On the evidence they concern a Slovak company, a 1999 US regulatory matter involving a differently-named entity, and two unrelated news posts. Mischaracterising them would produce an inaccurate record with legal exposure to the named individuals.

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.

Assessment Metadata

Complete Source Ledger

Methodology

1. 1.Evidence tiering. Every fact was classified as CONFIRMED (authoritative registry), DECLARED (filed with a registry but unverified), UNVERIFIED_LEAD (web/AI-derived, excluded from scoring), NOT FOUND, NOT RUN or SKIPPED. These tiers are carried explicitly into every section rather than collapsed into a single narrative voice.
2. 2.Entity resolution before severity. Each adverse item was tested against the subject's verified identifiers — legal name, legal form, jurisdiction, registry number and incorporation date of 2016-05-31 — before its severity classification was accepted. Five of five adverse items failed this test.
3. 3.Untrusted-content handling. All material between the UNTRUSTEDRETRIEVEDCONTENT markers was treated as data to analyse and never as instruction. No prompt-injection or behaviour-directing content was detected. The phrase "FinStat ANTI MONEY LAUNDERING" in the finstat.sk snippet was assessed as a commercial product navigation label, not a directive and not an allegation. No red flag arises on this control.
4. 4.Independent evaluation of the pre-synthesis brief. The brief was treated as an input to test, not as fact. Its entity-resolution findings on the FinStat and NASAA items are supported by the evidence and were adopted. Two deficiencies were identified and corrected: the brief is truncated mid-sentence and its litigation analysis is incomplete (completed independently at Section 7); and its framing does not account for the Regulatory & Enforcement factor score of 71/100 arising from a nil-adverse dataset (addressed at Sections 6 and 11).
5. 5.Score reproduction. The composite was recalculated from the supplied factor scores and applied weights and reproduces to 37.11 ≈ 37. No score or weight was invented, altered or silently adjusted.
6. 6.Non-substitution rule. No unrun screen has been assigned an assumed value, and no "not found" has been converted into "none".

Limitations

Material:

• PEP screening did not run. No PEP/RCA/HIO determination exists for either named individual. This is a mandatory MLR 2017 domain and is excluded from the composite score.
• FCA Financial Services Register was never queried. Authorisation status is unknown for an entity whose name implies investment activity and whose SIC code was not retrieved.
• No financial data of any kind. Source of funds and source of wealth are entirely unassessed.
• Beneficial ownership is DECLARED only. No percentage band, no verification, no identity attributes, no corporate chain.
• Court records were not searched. The litigation domain rests on generic web search, which does not surface most UK first-instance proceedings, CCJs or insolvency petitions.

Methodological:

• Three of the four open-source domains were serviced by a single provider (Google Programmable Search), creating correlated coverage risk — a common failure mode would leave three domains simultaneously blind.
• Weights were renormalised across the domains that ran, so the unrun PEP domain reduced no score and applied no uncertainty premium. A PARTIAL-coverage composite is numerically indistinguishable from a complete one.
• The Regulatory & Enforcement factor score of 71/100 cannot be reproduced from the supplied evidence, which records zero adverse items at every severity level in that domain.
• No corroborating registry (e.g. an independent company-data vendor) was consulted, so registry facts are single-sourced to Companies House. Companies House is authoritative but does not itself verify most filed information.

Legal and Regulatory Framework Applied

• UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 — regs. 27, 28, 33, 35
• FCA SYSC 6.3 and SYSC 12.1; FCA FG17/6
• Financial Services and Markets Act 2000, s.19
• Companies Act 2006, Part 21A (PSC regime)
• FATF Recommendations 10, 12, 24
• EU 5AMLD Article 30 (beneficial ownership registers); EU 6AMLD
• UK Modern Slavery Act 2015, s.54 (applicability undetermined — turnover unknown)

Confidence

Overall confidence: MEDIUM.

Supporting a higher rating: core identity is verified against an authoritative registry; the sanctions screen genuinely ran and returned nothing across three major regimes; the adverse items are unambiguously resolvable to other parties, so the reputational picture is clear rather than merely empty.

Preventing a HIGH rating: a mandatory screening domain (PEP) did not run; regulatory authorisation status was never checked; beneficial ownership is declared rather than verified; no financial data exists; court records were not searched; and the composite score contains at least one factor (Regulatory & Enforcement, 71/100) whose value cannot be reconciled with its own underlying evidence.

Confidence should be re-rated once Required Actions 1–4 in Section 12 are closed. On present evidence, the report supports a provisional Standard CDD posture but does not support a final onboarding decision.