INFINITUM CAPITAL LIMITED

Assessment

Core identity is VERIFIED against the authoritative UK registry. Everything beyond bare identity — business activity, financial scale, regulated status, trading premises — is NOT FOUND in the evidence set.

Registry Record

Identity Gaps — What Was Not Retrieved

The following registry attributes were not present in the supplied evidence. Each is retrievable from Companies House and each has a specific compliance consequence:

1. 1.SIC code / nature of business — the company's declared activity is unknown. Without it, no assessment of inherent sector risk, expected transaction profile or regulated-activity exposure is possible.
2. 2.Accounts filing status and latest accounts — whether the company files micro-entity, dormant, small or full accounts is a direct proxy for scale and activity. Dormancy would materially change the risk analysis. See Section 8.
3. 3.Confirmation statement / filing history — no evidence of filing currency or of any late-filing or strike-off history.
4. 4.Previous company names — a name change would explain search-result discontinuity and is a standard screening input.
5. 5.Share capital and shareholder list — not retrieved; bears directly on the ownership analysis in Section 2.
6. 6.Officer appointment and resignation history — only a current directorship was returned. Officer churn is a recognised structuring indicator and cannot be assessed.

The Registered Address

The address is recorded in the "C/O" form, indicating that the registered office is provided by a third party (Goldwyns London Llp) rather than being the company's own premises. This is lawful and routine for small UK companies. It nonetheless means:

• The registry address is not evidence of a place of business.
• The number of other companies registered at the same address was not retrieved and no conclusion about mass registration may be drawn either way.
• Verification of an actual principal place of business, and of the relationship with the LLP providing the address, is an outstanding CDD step.

Name-Collision Exposure

The entity name is a screening liability in itself. "Infinitum Capital" collides with at least one same-named foreign company (a Slovak s. r. o., see Section 5) and with the ordinary English phrase "ad infinitum. Capital…" (see Section 7). Any ongoing monitoring rule keyed to the name string alone will generate persistent false positives and will predictably desensitise reviewers. Monitoring must be keyed to company number 10206158 and to named officers.

Risk Implication

Identity is established to registry standard and is not itself a risk driver. The material issue is that the identity record is thin: without SIC code, accounts or regulated status, the firm cannot form a view on whether observed or expected activity is consistent with the customer's stated profile — the core obligation under MLR 2017 regulation 28(11)(a) and regulation 28(12).

Assessment

Control is partially established. One officer is CONFIRMED from the authoritative register; one person with significant control is DECLARED only — filed by the company and not independently verified by Companies House or by this assessment. No ownership percentage, nature of control, or corporate chain was retrieved.

Recorded Persons

These classifications must not be conflated. A CONFIRMED directorship establishes an officer appointment on the register; it does not establish ownership. A DECLARED PSC entry establishes only that the company made a filing to that effect. Neither entry has been verified against identity documentation in this assessment.

The 25% Threshold

Under the UK PSC regime a person must be registered where they, directly or indirectly:

• hold more than 25% of the shares; or
• hold more than 25% of the voting rights; or
• hold the right to appoint or remove a majority of the board; or
• otherwise exercise, or have the right to exercise, significant influence or control.

The evidence records that Shruti Luthra is registered as a PSC but does not record which of these conditions applies, nor the banded percentage (25–50%, 50–75%, over 75%). That band is a standard PSC register field and its absence from the evidence set is a retrieval gap, not necessarily a filing gap.

Structural Questions That Remain Open

1. 1.Is the disclosed PSC the ultimate natural person? No corporate chain was retrieved. If shares are held through an intermediate vehicle, that layer is invisible in the current evidence.
2. 2.Is the PSC list complete? A single PSC does not preclude other holders below the 25% threshold who may nonetheless exercise influence.
3. 3.What is the relationship between the director and the PSC? Not established. Where a director and a controller are distinct persons, the governance and instruction-taking arrangement is a relevant CDD input.
4. 4.Are there other directors or former directors? Only one current officer was returned; historical officers were not retrieved.

Regulatory Framework

• FATF Recommendation 24 — obliges countries to ensure adequate, accurate and timely beneficial-ownership information. It does not permit a firm to treat registry data as verified beneficial ownership.
• UK MLR 2017 regulation 28(4) — the firm must identify the beneficial owner and take reasonable measures to verify identity so that it is satisfied it knows who the beneficial owner is. Reliance on the PSC register alone is expressly insufficient.
• EU 5AMLD Article 30 — establishes the register-based transparency regime the UK PSC register parallels; retained relevance for cross-border counterparties.
• MLR 2017 regulation 30A — creates a discrepancy-reporting duty. If the firm's own verification produces a beneficial owner different from the register, that discrepancy must be reported to Companies House.

Risk Implication

The opacity here is moderate, not severe: a UK ltd with one director and one registered PSC is a simple structure on its face, and no nominee or offshore layer is evidenced. But "not evidenced" is not "absent". Until Shruti Luthra's identity, holding band and nature of control are independently verified, the firm has not discharged regulation 28(4), and the entity's Transparency Risk score of 8/100 (Section 11) should be treated as provisional and optimistic. This also directly limits Section 3: sanctions screening of a beneficial owner is only as reliable as the beneficial-owner identification underlying it.

Assessment

Screen status: RAN — genuine nil return. This is the strongest and most reliable clean signal in the file.

Screening Record

Interpretation

• This is an OK_EMPTY, not a FAILED or SKIPPED result. Under the ledger definitions supplied, the source ran and genuinely found nothing. It is therefore a real negative finding and may be relied upon for the corporate name.
• No exact match and no possible name match were returned. The distinction matters: a possible-match-cleared result would require documented adjudication; here there was nothing to adjudicate.

Qualifications — Read Before Relying On This

1. 1.Scope of the individuals screened is not stated. The evidence does not confirm whether BHATNAGAR, Dhruv and Shruti Luthra were screened as individuals against the same lists, or whether only the corporate name string was run. Under MLR 2017 and the OFSI/UK sanctions regime, screening must extend to beneficial owners and controllers. This must be confirmed in writing before the nil result is recorded as covering the individuals.
2. 2.List coverage is limited to three regimes. EU consolidated, and other national or sectoral lists (including UK sectoral/investment restrictions), are not itemised in the ledger. For a UK entity with a name suggesting investment activity, sectoral sanctions screening is relevant.
3. 3.Ownership uncertainty limits sanctions certainty. Because beneficial ownership is only partially established (Section 2), a nil sanctions return cannot exclude indirect control by a designated person through an unverified layer. The ownership limitation in Section 2 materially constrains the assurance available from this section.
4. 4.50% Rule. OFAC's 50 Percent Rule and the equivalent UK ownership-and-control provisions capture entities owned or controlled by designated persons even where the entity itself is not listed. Applying that test requires verified ownership data, which is not available.

Risk Implication

Sanctions risk is assessed as low on current evidence and carries the highest applied weight in the model (34.1%), which is the principal reason the composite score sits at 13/100. That weighting is only defensible if the screen genuinely covered the natural persons as well as the corporate entity. Confirm scope; if only the entity name was screened, re-run against both individuals before the score is relied upon.

Assessment

Screen status: NOT RUN

No PEP screening was performed. The source ledger records: "No PEP screening provider configured [PEP] → SKIPPED". No PEP, Relative or Close Associate (RCA), or High-Profile/Head of International Organisation (HIO) determination exists for this entity or for any person connected to it.

What This Means Precisely

This report does not state that the entity or its officers are not PEPs. It states that this was never tested. Any file note recording "PEP: clear" on the basis of this assessment would be inaccurate and would misrepresent the control environment to the regulator.

Regulatory Framework and Consequence

• FATF Recommendation 12 — requires financial institutions to have risk-management systems to determine whether a customer or beneficial owner is a PEP, and, where so, to obtain senior management approval, establish source of wealth and source of funds, and conduct enhanced ongoing monitoring.
• FCA SYSC 12.1 / SYSC 6.3 — requires adequate systems and controls for financial crime risk across the firm.
• UK MLR 2017 regulations 33 and 35 — mandate enhanced due diligence in any business relationship with a PEP, a family member or a known close associate. If either named individual is a PEP, the correct CDD outcome changes from Standard CDD to mandatory EDD with senior-management sign-off. The current Standard CDD recommendation is therefore conditional on this screen being completed.

Required Action

1. 1.Run PEP/RCA/HIO screening against a licensed provider for BHATNAGAR, Dhruv and Shruti Luthra, including foreign-jurisdiction PEP coverage.
2. 2.Record the provider, list version and screening date on file.
3. 3.If any positive or possible match is returned, escalate immediately to EDD under regulation 35 and re-score the composite with the PEP domain included.
4. 4.Remediate the configuration gap — a screening pipeline with no PEP provider is a systemic control weakness affecting the entire book of business, not just this file, and should be escalated to the MLRO independently of this review.

Assessment

The adverse-media screen ran and returned data, but on inspection neither of the two items classified adverse resolves to INFINITUM CAPITAL LIMITED (10206158). The correct characterisation of this domain is "not effectively tested", not "clean".

Screen Parameters

The Two Adverse Items — Item-Level Adjudication

Item 1 — FinStat.sk company profile [HIGH severity as classified]

• Publication/source: FinStat.sk (Slovak company-data platform), https://finstat.sk/56739036
• Snippet date reference: 29 January 2025; item otherwise UNDATED
• Subject named: "INFINITUM CAPITAL s. r. o."
• Allegation type: None. The snippet reports profit, revenue and economic results, followed by the site's own navigation menu: "FinStat ANTI MONEY LAUNDERING · FinStat INTELIGENTNÝ REPORTING".
• Resolution to subject: NO. s. r. o. is a Slovak legal form. The record carries a separate registry identifier (56739036) in a separate national registry. No link to UK company 10206158 is stated anywhere in the evidence.
• Finding: This is a classification defect. A keyword-driven classifier has read a vendor's product name ("ANTI MONEY LAUNDERING") as adverse content. There is no allegation, no investigation, no charge and no conviction in this item. It should be reclassified as neutral and the defect raised as a pipeline issue.

Item 2 — NASAA, "Securities Frauds on the Internet" [HIGH severity as classified]

• Publication/source: North American Securities Administrators Association, https://www.nasaa.org/911/securities-frauds-on-the-internet-and-current-issues-concerning-online-trading/
• Date: 23 March 1999
• Content as reported: NASAA states that, in response to initial investigation by the Pennsylvania Securities Commission, the SEC initiated an enforcement action concerning an entity abbreviated "AIF". This is reported as a publication's account of an enforcement action; it is attributed here and not asserted as established fact against any party.
• Resolution to subject: NO. The item predates the subject's incorporation (31 May 2016) by approximately seventeen years. Attribution to this entity is chronologically impossible. The named abbreviation "AIF" does not correspond to the subject.
• Finding: False positive. No adverse inference against INFINITUM CAPITAL LIMITED is available from this item.

The Eight Neutral Items

Eight results were classified neutral. Their sources, dates and content were not supplied in the evidence set. This is a retrieval limitation: the firm cannot confirm from this report whether any neutral item positively corroborates the subject's business activity, or whether all ten results are name-collisions with unrelated parties. Given that both adverse items are collisions, the working assumption must be that subject-specific media coverage is close to nil.

AML/CTF Relevance

None established. No allegation of money laundering, terrorist financing, fraud, bribery or sanctions evasion has been made against this entity in the retrieved material. Equally, no source has affirmatively examined and cleared it.

Risk Implication

The Adverse Media domain score of 4/100 is arithmetically consistent with the classifier output but is not evidentially meaningful, because the classifier was measuring the wrong entities. The practical consequences:

1. 1.Confidence, not score, is the correct place to record this. The score stays low; confidence drops to LOW.
2. 2.Name-collision management is now an operational requirement. Ongoing monitoring keyed to "Infinitum Capital" will recur with Slovak-entity and "ad infinitum" noise indefinitely (see Section 7). Configure monitoring on company number, registered address and officer names.
3. 3.A targeted, subject-specific media search should be run — combining the company number, the registered office and the officer names — before this domain is treated as tested.

Assessment

No regulatory or enforcement action against INFINITUM CAPITAL LIMITED was identified. However, this conclusion rests entirely on a general web search. No statutory regulatory register was queried, which is a material limitation for a UK entity operating under the word "Capital".

Screen Record

What Was NOT Checked — and Why It Matters

The following authoritative registers do not appear in the source ledger and were therefore not consulted:

Interpretation Discipline

The Regulatory domain score of 18/100 reflects a nil adverse return from a web search, not a nil return from a regulator's own register. Under the evidence conventions applied in this report:

• The correct status is NOT FOUND, not VERIFIED CLEAR.
• A general search engine will not reliably surface an FCA supervisory notice, a requirement notice, a variation of permission or an unauthorised-business warning.

Cross-Reference

The two items in Section 5 that were classified adverse both concern securities-regulatory subject matter (the 1999 NASAA/SEC item) or a foreign company registry (FinStat.sk). Neither resolves to this entity, and consequently neither supports any regulatory-history inference here. The regulatory screen's nil adverse return is consistent with — but does not independently confirm — that conclusion.

Risk Implication

No regulatory adverse finding exists on the current evidence. The residual risk is the unverified authorisation status. This is a low-cost, high-value check: a single FCA Register query on company number 10206158 and on the named director resolves it. Until it is completed, the firm cannot state whether it is dealing with a regulated counterparty, an unregulated holding vehicle, or a firm conducting regulated activity without permission.

Assessment

No litigation involving INFINITUM CAPITAL LIMITED was identified. The Litigation domain carries the highest raw domain score in the model (41/100), but that score is generated by three items with no probative value against this entity — two are grammatical string collisions and one is a funding announcement misclassified as litigation. Court records were not searched directly.

Screen Record

Item-Level Adjudication

Why items 2 and 3 are not entity references

Both snippets contain the identical recycled sentence fragment: "Ad infinitum. Capital improvement surcharges would not be…". The apparent match is a sentence boundary — the Latin adverb ad infinitum ending one sentence and the noun Capital beginning the next. These are not references to any company. They carry zero evidential weight and should be reclassified.

Why item 1 is not litigation

The Ayar Labs article is a funding announcement, not a legal proceeding. The word "lawsuit" appears only in an unrelated sidebar headline ("Innoscience files lawsuit against Infineon") — a page-furniture artefact of the publisher's site template. No lawsuit involving any Infinitum Capital is reported in this item.

Item 1 is nonetheless the only retrieved item with genuine potential relevance to the subject, but as business-activity evidence rather than litigation evidence. If the "Infinitum Capital" named as a Series C participant is company 10206158, it would be the sole open-source indication of the entity's actual business (venture investment). That identification is unresolved — the article does not state a jurisdiction, registration number or address, and "Infinitum Capital" is a name known to be shared with at least one foreign entity (Section 5). See Section 8.

Patterns Specifically Assessed

Risk Implication

1. 1.The 41/100 domain score overstates measured litigation risk. It contributes approximately 4.67 points to the composite (Section 11) on the basis of items that concern New York rent regulation, Trinidadian market vendors and a semiconductor funding round. Correcting for this would push the composite below 10.
2. 2.But the correct conclusion is "not tested", not "clean". No English court record, judgment register or insolvency register was searched. A UK entity's litigation exposure cannot be established from a general web search.
3. 3.Recommended step: search the Register of Judgments, Orders and Fines and the Companies House / Gazette insolvency records against company number 10206158 before recording this domain as assessed.

Assessment

Screen status: NOT RUN

No dedicated ESG, sustainability or conduct data source was consulted. The source ledger contains no ESG provider, no modern-slavery registry query, no environmental-regulator lookup and no data-breach notification source. Any ESG-relevant signal in this file would have arrived only incidentally through general web search.

Domain-by-Domain Position

Governance Observations Drawn From Registry Evidence

These are the only conduct-relevant observations the evidence supports, and they are structural rather than adverse:

1. 1.Single recorded director. Only one officer (BHATNAGAR, Dhruv) was returned. Sole-director companies have no internal board challenge mechanism. This is lawful and extremely common; it is noted as a governance characteristic, not a finding of misconduct.
2. 2.Registered office provided by a third party. Indicates outsourced corporate administration; not adverse in itself.
3. 3.Beneficial ownership declared but unverified. Transparency is the ESG dimension most directly engaged here, and it is addressed under Transparency Risk in Section 11.

Applicable Frameworks — and Their Current Applicability

Risk Implication

ESG and conduct risk is UNDETERMINED. It is not a weighted factor in the scoring model (Section 11) and therefore does not affect the composite score. That is a modelling choice, not a statement that ESG risk is absent. For a counterparty of unknown sector, size and operating geography, ESG exposure cannot be meaningfully bounded. If the entity is confirmed to be a venture investor (see the unresolved Ayar Labs datapoint, Sections 7 and 8), portfolio-level ESG and conduct exposure would become relevant and would warrant a dedicated screen at that point.

Assessment

No financial information about INFINITUM CAPITAL LIMITED was retrieved. This is a due-diligence deficiency, explicitly flagged. Source of funds and source of wealth are unestablished.

Screen Record

Data Points Sought and Not Found

The One Potentially Relevant Financial Datapoint

The Ayar Labs article (Section 7) names "Infinitum Capital" among participants in a $130M Series C round, alongside Nautilus Venture Partners and Tyche Partners [Source: compoundsemiconductor.net, https://compoundsemiconductor.net/article/114667/AyarLabsRaises130MinSeriesC_Funding; snippet dated 27 Apr 2022].

Handling instructions for this datapoint:

• This is an outbound investment by an entity of that name, not an inbound funding round for the subject. It does not evidence the subject's own capitalisation.
• Identification with company 10206158 is UNVERIFIED. The article supplies no jurisdiction, registration number or address. Given the demonstrated name-collision problem in this file, attribution must not be assumed.
• If verified, it would establish venture-capital investment as the business activity, would raise the question of investor capital origin, and would make the FCA authorisation check in Section 6 more urgent — deploying third-party capital into private companies may engage regulated activity.
• No investment amount attributable to any Infinitum Capital is stated. Do not record a figure.

Red-Flag Assessment Against Standard Indicators

Regulatory Position

Under MLR 2017 regulation 28(11)(a) the firm must obtain information on the purpose and intended nature of the business relationship, and under regulation 28(12) conduct ongoing monitoring to ensure transactions are consistent with the firm's knowledge of the customer's business and risk profile. Neither obligation can currently be met: the firm has no knowledge of the customer's business or financial profile beyond its legal form.

Risk Implication

The absence of adverse financial findings must not be read as financial health. It reflects that no financial record was located. Obtaining the filed accounts from Companies House and a written source-of-funds statement from the customer are the two minimum steps before any account activity is permitted. This gap is the principal reason the confidence rating for this report is LOW rather than MEDIUM.

Assessment

The entity's sole evidenced jurisdictional nexus is the United Kingdom — a FATF member with a mature AML/CFT regime. No operating jurisdictions outside the UK were evidenced. No offshore structure was identified, and none was excluded.

Evidenced Jurisdictional Facts

Reference Datasets — Disclosure of What Was Consulted

No dedicated jurisdictional-risk reference dataset was queried in this assessment. The source ledger contains no FATF list feed, no EU high-risk third-country list and no Transparency International CPI lookup. Accordingly:

The Slovak Collision — Explicitly Not a Jurisdictional Nexus

The adverse-media screen returned "INFINITUM CAPITAL s. r. o.", a Slovak-registry entity (FinStat ID 56739036, https://finstat.sk/56739036). This does not create a Slovak jurisdictional exposure for the subject. No evidence of common ownership, control, group membership or any other relationship was retrieved. It is recorded here solely so that the file is unambiguous that Slovakia was considered and rejected as a nexus. See Section 5.

Similarly, the United States (NASAA/SEC 1999) and Trinidad and Tobago (San Juan vendors, 2019) appear only through false-positive matches and create no jurisdictional exposure.

Model Score

The model assigns Jurisdiction Risk 35/100 at an applied weight of 6.8%, contributing 2.38 points to the composite. The evidence supports a low-to-moderate jurisdiction score for a UK-incorporated entity. However, the score is calculated on country of incorporation only; because operating jurisdictions, officer nationality and any group structure are unknown, the score reflects the registered footprint and not necessarily the actual one.

Risk Implication

UK incorporation is not itself a low-risk indicator in any absolute sense — UK limited companies are a well-documented vehicle for cross-border laundering precisely because incorporation is cheap and registry data is unverified. The mitigating factors here are the professional-services registered office and the presence of a registered PSC; the aggravating factor is the complete absence of evidence about where the company actually operates. Establishing the true operating footprint is a required CDD step (Section 12).

Composite Result

Weighted Factor Table

Scores and applied (renormalised) weights are reproduced verbatim from the supplied risk-score block.

Calculation

Composite Score = Σ(Factor Score × Applied Weight)

`` Sanctions & Watchlists 3 × 0.341 = 1.023 Adverse Media 4 × 0.227 = 0.908 Regulatory & Enforcement 18 × 0.204 = 3.672 Politically Exposed Persons UNDETERMINED — screen did not run, no weight applied Litigation 41 × 0.114 = 4.674 Jurisdiction Risk 35 × 0.068 = 2.380 Transparency Risk 8 × 0.045 = 0.360 ─────── Composite = 13.017 → 13 / 100 (LOW band) ``

Applied weights sum to 99.9% (34.1 + 22.7 + 20.4 + 11.4 + 6.8 + 4.5); the residual 0.1% is rounding in the published weights. The arithmetic reproduces the supplied composite exactly.

What Actually Drives the Score

Downward pressure (legitimate):

• Sanctions nil return at 34.1% weight contributes only 1.02 points — this is a real, verified clean signal and it does most of the work.
• Regulatory nil-adverse return at 20.4% weight.

Upward pressure (largely artefactual):

• Litigation at 4.67 points is the largest single contributor to the score and is entirely non-probative. Removing the three false positives would reduce the composite to approximately 8/100.
• Jurisdiction at 2.38 points reflects a baseline UK score, not an identified exposure.

Why the Number Overstates the Assurance

The score is arithmetically correct and evidentially fragile. Three structural issues:

1. 1.A 22.7%-weighted domain (Adverse Media) and an 11.4%-weighted domain (Litigation) — 34.1% of the model combined — produced no observation about the subject at all. Their scores measure a false-positive cluster generated by a generic name.
2. 2.PEP, a mandatory risk domain, is absent from the model. The composite is a six-factor result presented in a seven-factor frame. It must never be described as a complete assessment.
3. 3.Transparency Risk at 8/100 is not supported by the underlying evidence. A file with an unverified PSC, no SIC code, no accounts, no OSINT footprint and a c/o address is not an 8/100 transparency case on any defensible reading. This factor carries only 4.5% weight, so correcting it would not change the band — but it signals that the transparency sub-model is under-sensitive to registry-data gaps and should be reviewed.

Conclusion

The LOW band is retained. No evidence in this file supports a higher band: there is no sanctions match, no regulatory action, no verified litigation and no credible adverse media against company 10206158. The band is stated with LOW confidence because two adverse domains were not effectively tested, one mandatory domain was not run, and no financial evidence exists. This is a low-risk-on-current-evidence assessment, not a low-risk-verified assessment, and the file note should say so in those terms.

Recommendation

STANDARD CDD — conditional. Do not record the file as complete until the five Required Actions below are closed.

• CDD level: Standard Customer Due Diligence (MLR 2017 reg. 27–28)
• Enhanced Due Diligence required: NO on current evidence — but conditionally triggered if PEP screening returns a match (reg. 33/35)
• Monitoring frequency: ANNUAL, with the configuration caveat below
• Next scheduled review: 18 August 2027
• Interim review: 17 September 2026 — to confirm closure of the outstanding actions
• Escalation required now: Yes — to the MLRO, for the systemic PEP-provider configuration gap, which affects the whole book of business and not merely this file

Rationale

Why Standard and not EDD:

Nothing in the retrieved evidence meets the regulation 33 triggers. The sanctions screen returned a genuine nil result (Section 3); no regulator has taken action (Section 6); no litigation involving the subject exists in the retrieved material (Section 7); the jurisdiction is a FATF member with no high-risk designation (Section 9). Escalating to EDD on the strength of five false-positive matches would be an unjustified and unevidenced imposition on the customer, and would misallocate scarce EDD resource.

Why Standard CDD cannot yet be signed off:

Standard CDD still requires the firm to (i) identify and verify the customer, (ii) identify the beneficial owner and take reasonable measures to verify, and (iii) obtain information on the purpose and intended nature of the relationship. None of (ii) or (iii) is currently satisfied. In addition, PEP determination is not optional and has not been performed.

Why rejection is not recommended:

The deficiencies are informational, not adverse. No evidence of criminality, sanctions exposure or regulatory breach exists. Declining on the basis of unretrieved data would not be evidence-led.

Outstanding Information Gaps

Required Actions

1. 1.Run PEP/RCA/HIO screening against a licensed provider for BHATNAGAR, Dhruv (director, CONFIRMED) and Shruti Luthra (PSC, DECLARED). Record provider, list version and date. Priority: immediate. If any match returns, escalate to EDD with senior-management approval before proceeding.
2. 2.Query the FCA Financial Services Register and FCA Warning List for company number 10206158 and for the named director. Record permissions, appointed-representative status or absence thereof. Priority: immediate.
3. 3.Verify beneficial ownership independently of the register. Obtain certified identification for Shruti Luthra, confirm the PSC holding band and nature of control, obtain a signed ownership structure chart confirming no intermediate corporate layer, and confirm whether any additional PSCs exist. Apply the reg. 30A discrepancy-reporting test to the result. Priority: pre-onboarding.
4. 4.Obtain the full Companies House record — SIC code, latest filed accounts, filing history, share capital and officer history — together with a customer-signed statement of business activity, expected transaction volumes and source of funds. Confirm whether accounts are filed as dormant, and if so reconcile that against any claimed investment activity. Priority: pre-onboarding.
5. 5.Run authoritative legal-record searches: Register of Judgments, Orders and Fines; Companies House insolvency record; London Gazette; disqualified-directors register. Priority: pre-onboarding.

Supplementary action (portfolio-level, not customer-level)

1. 1.Raise two screening-pipeline defects with the MLRO: (a) no PEP provider is configured, which is a systemic control failure; (b) the classifier scored a vendor's product-menu text ("FinStat ANTI MONEY LAUNDERING") as a HIGH-severity adverse hit, and scored two English-language sentence-boundary collisions as MEDIUM litigation hits. Both defects will recur across the book of business.

Monitoring Configuration — Mandatory Caveat

Annual review frequency is appropriate to a LOW-band file. However, ongoing monitoring must NOT be keyed to the name string "Infinitum Capital". The evidence demonstrates that this string collides with at least one same-named foreign company and with common editorial phrasing, and will generate persistent noise that predictably desensitises reviewers. Configure alerts on:

• Company registration number 10206158
• Officer names BHATNAGAR, Dhruv and Shruti Luthra
• The registered office address, as a secondary discriminator

Trigger Events for Immediate Off-Cycle Review

• Any PEP, sanctions or watchlist match on the entity or either named individual
• Any change of director, PSC, registered office or company name at Companies House
• Any FCA Register status change, warning-list appearance or enforcement publication
• Filing of a first set of accounts, or a change in accounts filing category (e.g. dormant to trading)
• Any insolvency event, winding-up petition, strike-off notice or CCJ
• Transaction activity materially inconsistent with the declared business profile, once that profile is obtained
• Credible adverse media that verifiably resolves to company number 10206158
• Confirmation or refutation of the entity's identity as the "Infinitum Capital" named in the Ayar Labs Series C announcement (Sections 7 and 8)

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 Date

18 August 2026. All findings are as at that date. Coverage status: PARTIAL.

Complete Source Ledger

Ledger key: OKDATA = ran, returned data. OKEMPTY = ran, genuinely found nothing (a real clean signal). FAILED = did not run; no conclusion may be drawn. SKIPPED = not applicable or not configured.

Note: No source in this assessment returned a FAILED status. The gaps arise from sources that were skipped or never configured, which is a different and — for the PEP domain — more serious control finding, because it is systemic rather than transient.

Methodology

1. 1.Registry anchoring. Legal identity was fixed to a single authoritative record (UK Companies House, company number 10206158). All subsequent findings were tested for resolution against that anchor.
2. 2.Entity-resolution adjudication. Every item classified adverse by the automated screens was individually examined for jurisdiction, legal form, date and named parties. Items that could not be reconciled to company 10206158 were reported as non-resolving and excluded from adverse inference — while being explicitly retained in the report so the reader can audit the reasoning rather than take the exclusion on trust.
3. 3.Chronological testing. Items were tested against the incorporation date of 31 May 2016. Items predating incorporation were treated as incapable of attribution.
4. 4.Verification-status discipline. Registry-confirmed, self-declared and web-derived data were kept categorically distinct throughout. No DECLARED entry is described as verified anywhere in this report.
5. 5.Source-attribution discipline. Every adverse assertion is attributed to the publication that made it. No allegation is presented as established fact. No item in this file has been determined by any court or regulator against this entity.
6. 6.Coverage-honest scoring. The supplied composite was reproduced verbatim and its arithmetic verified independently (13.017 → 13). Unrun domains were left as UNDETERMINED and no value was imputed.
7. 7.Injection review. All content between the UNTRUSTEDRETRIEVEDCONTENT markers was reviewed for instruction-like or behaviour-directing content. None was found. No prompt-injection attempt is reported. A separate classifier defect was identified and is recorded in Sections 5 and 12.

Limitations

Material — affect the reliability of the conclusion:

1. 1.PEP screening was not performed. A mandatory risk domain under FATF R.12 and MLR 2017 reg. 33/35 is entirely absent and is excluded from the composite.
2. 2.The adverse-media and litigation domains did not test the subject. Four of five adverse items demonstrably concern other parties, other decades or ordinary prose; the fifth is unresolved. Together these domains carry 34.1% of the applied model weight.
3. 3.No financial evidence of any kind. Source of wealth and source of funds are unestablished; MLR 2017 reg. 28(11)(a) and 28(12) cannot currently be met.
4. 4.Beneficial ownership is declared, not verified. No holding percentage, nature of control or corporate chain was retrieved.
5. 5.No authoritative regulatory or legal register was queried — only general web search stood in for the FCA Register, court records and insolvency registers.

Contextual:

1. 1.Name-collision exposure. "Infinitum Capital" collides with a same-named Slovak entity and with the phrase "ad infinitum. Capital", degrading all name-based screening and all future monitoring keyed to the string.
2. 2.Neutral and positive search items were not itemised in the supplied evidence, so no corroborating detail could be extracted from the 21 non-adverse results across the four web screens.
3. 3.Nil OSINT footprint means no independent corroboration of trading substance exists.

Conflicting records: None identified. No supplied source contradicts another; the difficulty in this file is non-attribution, not contradiction.

Confidence

Overall confidence: LOW.

The principal reasons:

• Identity and legal status are established to a high standard (registry-verified), and the sanctions nil return is genuine and reliable. Those two elements alone would support MEDIUM confidence.
• Confidence is reduced to LOW because a mandatory domain (PEP) was never screened; because the two domains most likely to surface reputational and legal risk produced no observation about the subject; because there is no financial evidence; and because beneficial ownership rests on an unverified self-declared filing.

The composite score of 13/100 should therefore be read as "no adverse evidence identified within a partial and partially ineffective evidence set", not as "verified low risk". Confidence can be raised to MEDIUM once Required Actions 1–3 in Section 12 are closed, and to HIGH once Actions 4 and 5 are also closed.

Legal and Regulatory Framework Applied

• UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 — regs. 27–28 (CDD), 28(4) (beneficial ownership verification), 28(11)–(12) (purpose of relationship and ongoing monitoring), 30A (discrepancy reporting), 33 and 35 (EDD and PEPs)
• FATF Recommendations — R.10 (CDD), R.12 (PEPs), R.24 (transparency and beneficial ownership of legal persons)
• FCA Handbook — SYSC 6.3 (financial crime systems and controls), SYSC 12.1 (group-wide systems)
• Financial Services and Markets Act 2000 — s.19 (general prohibition on carrying on regulated activity without authorisation)
• EU 5AMLD Article 30 — beneficial-ownership register regime (comparator framework)
• EU 6AMLD — predicate-offence framework (comparator)
• UK Modern Slavery Act 2015 s.54, CSRD, TCFD, UN Global Compact — referenced in Section 10; applicability undetermined pending scale data