INFINITUM CAPITAL LIMITED

Assessment

Core registry identity is VERIFIED from an authoritative primary source. Everything beyond the registry record — activity, substance, regulatory status and financial position — is NOT FOUND.

Evidence

Key Findings

• The subject is an active UK private limited company of approximately ten years' standing as at the report date of 18 August 2026.
• The registered office is a care-of address at a professional firm (Goldwyns London LLP) at a prestige City of London location. This is a service address, not evidence of an operational presence. It is entirely lawful and extremely common for UK companies.
• No SIC code or stated nature of business was retrieved. This is material: the trading name contains "Capital", which signals investment or capital-markets activity, but the file contains nothing against which that implication can be tested.
• No filing history was retrieved — no accounts, no confirmation statement date, no dormancy or small-company exemption status, no auditor. For an entity incorporated in 2016, Companies House would ordinarily hold several years of filings.

Risk Implication

Identity verification of the legal person is satisfied for MLR 2017 reg. 28(3) purposes: name, number, type, status and registered office are all confirmed against the statutory register.

What is not satisfied is reg. 28(11)(a) — understanding the nature of the customer's business. Without a SIC code, accounts, or any OSINT footprint, the firm cannot articulate what this company does, and therefore cannot set a meaningful expected activity profile for ongoing monitoring. The absent SIC code also prevents the resolution of the single most consequential open question in this file, identified in Section 8: whether the entity is a venture-capital investor (which would materially change source-of-funds enquiries) or a dormant/holding vehicle.

The null OSINT return is recorded as NOT FOUND, not as a clean result. It means the search produced nothing, not that nothing exists.

Assessment

Two natural persons are named. One is confirmed in a management role; one is declared but unverified in a control role. No corporate chain, no ownership percentage and no nature-of-control statement was retrieved. Beneficial ownership is therefore partially identified and not verified.

Evidence

Not retrieved for either individual: date of birth (month/year), nationality, country of residence, service address, appointment or notification dates, other directorships.

Not retrieved for the PSC entry: ownership percentage band, voting-rights band, nature-of-control statement, whether control arises by shareholding, voting rights, right to appoint/remove directors, or significant influence.

The 25% Threshold

Under the UK PSC regime (Companies Act 2006 Part 21A) and MLR 2017 reg. 5, a person is a beneficial owner of a body corporate where they hold, directly or indirectly, more than 25% of the shares or voting rights, or otherwise exercise significant influence or control. FATF Recommendation 24 and EU 5AMLD Article 30 impose equivalent expectations on registry accuracy and firm-level verification.

The evidence does not state which limb of the 25% test Shruti Luthra satisfies, nor the percentage band held. That field is the discriminating detail — its absence means the firm knows that a controller has been declared, but not how control is exercised or at what level.

Governance Asymmetry

The confirmed director and the declared controller are different named individuals with different surnames. On the evidence:

• the person who runs the company does not appear as a controller;
• the person who controls the company does not appear as an officer.

This is a legitimate and commonplace arrangement (family holding, nominee structure, passive investment vehicle). The evidence contains no information whatsoever about the relationship between these two persons, and none is inferred here. What the split does require is verification, because the entire control layer of the company rests on an unverified self-declaration.

The pre-synthesis brief's characterisation of one individual by reference to an inferred national origin is unsupported by any evidence in this file and has been excluded — no nationality data was retrieved for either person.

Risk Implication

• A DECLARED PSC entry does not discharge MLR 2017 reg. 28(4)(a), which requires the firm to take reasonable measures to verify beneficial ownership so that it is satisfied it knows who the beneficial owner is. Companies House does not verify PSC filings substantively at the point of submission; reliance on the register alone is expressly insufficient.
• The missing date-of-birth, nationality and residence fields make any downstream screening nominal rather than discriminating. This directly degrades the sanctions position in Section 3 and makes the unrun PEP screen in Section 4 even harder to close, since name-only screening of common names produces unusable false-positive volumes.
• No corporate chain was identified and no intermediate holding entity appears in the evidence. This is NOT FOUND, not confirmation that the ownership chain is flat.

Required Next Steps

1. 1.Obtain the full PSC record including nature-of-control statement and percentage band.
2. 2.Verify the identity of Shruti Luthra independently of the self-filed register entry.
3. 3.Obtain DOB (month/year), nationality and country of residence for both individuals to enable discriminating screening.
4. 4.Confirm whether any further officers or PSCs exist that were not returned in this extract.

Assessment

This is the only domain in the file where the absence of findings is a genuine clean signal.

Screening Detail

No list name, entry date, designation reason or match confidence is reported, because no match of any kind was returned. There is no possible-match to adjudicate.

Key Findings

• The screen ran and genuinely returned nothing (OK_EMPTY, distinguished in the ledger from FAILED). This is a meaningful negative result and is correctly reflected in the near-floor subscore of 3/100.
• EU and other national lists are not named in the ledger. Only OFAC, UK OFSI and UN are recorded. Firms with EU nexus or with sectoral exposure should confirm whether EU, Swiss, Canadian and Australian lists form part of their screening estate.
• Screening scope against individuals is uncertain. The ledger records a sanctions screen without specifying whether BHATNAGAR, Dhruv and Shruti Luthra were screened individually or only the corporate name. Given the identifier gaps documented in Section 2 (no DOB, no nationality, no residence), any individual-level screening that did occur would have been name-only and therefore of limited discriminating power.

Risk Implication

No designation risk was identified for the entity as at the screening date. Under MLR 2017 and the UK sanctions regime (SAMLA 2018), sanctions screening is a point-in-time control: this result expires immediately and requires re-screening on the monitoring cycle and on any change of control.

The ownership position in Section 2 materially qualifies this result. UK OFSI's 50% ownership/control rule means an entity can be caught by a designation applying to a controller. Because the declared controller is unverified and no percentage band was retrieved, the firm cannot currently demonstrate that it has screened the correct control layer.

Required next step: confirm that both named natural persons were screened individually against the full list estate, with DOB and nationality identifiers, and record the outcome.

Assessment

Screen status: NOT RUN

No PEP screening was performed on this entity or on either named natural person. No conclusion of any kind — positive or negative — may be drawn about PEP, RCA or HIO status.

Evidence

Key Findings

• The absence of a PEP finding in this report is an absence of screening, not an absence of exposure. The two are not interchangeable.
• No role-keyword inference has been made and none should be. This report does not state that either individual is not a PEP, because that determination has not been made.
• The identifier gaps recorded in Section 2 (no date of birth, no nationality, no country of residence) mean that when a PEP screen is eventually run, it will be name-only unless those fields are first obtained. Name-only PEP screening of common names produces false-positive volumes that are typically unusable for a defensible decision.

Regulatory Implication

• MLR 2017 reg. 35(1) requires a relevant person to have appropriate risk-management systems and procedures to determine whether a customer or the beneficial owner of a customer is a PEP, a family member of a PEP or a known close associate of a PEP. No such determination has been made here.
• FATF Recommendation 12 requires equivalent measures for foreign PEPs and a risk-based approach for domestic PEPs and international organisation officials.
• FCA SYSC 12.1 and SYSC 6.3 require adequate systems and controls to identify and manage financial crime risk across the business.

A relationship cannot be defensibly onboarded on the basis of a screening file in which an entire mandatory domain was not executed. If the PEP screen subsequently returns a match, the CDD level, the composite score in Section 11 and the recommendation in Section 12 all require re-derivation.

Required Next Step

Procure and run PEP/RCA screening on both named individuals before any onboarding decision is finalised. Obtain DOB (month/year), nationality and country of residence first so that the screen is discriminating rather than nominal.

Assessment

The adverse-media domain returned 10 results: 2 adverse (both classified HIGH), 0 positive, 8 neutral. On analysis, neither adverse item attaches to INFINITUM CAPITAL LIMITED (10206158). Both are name collisions. The correct finding for this domain is NOT FOUND, not "clean", because the search that ran was a general web search rather than a structured adverse-media database.

Adverse Items — Attribution Analysis

Key Findings

• The FinStat item contains no allegation. It is a financial-directory listing for a Slovak company. Its classification as HIGH-severity adverse media is a classification error, not a finding. The only text resembling AML terminology is the site's own navigation menu ("FinStat ANTI MONEY LAUNDERING · FinStat INTELIGENTNÝ REPORTING") — boilerplate, not an assertion about any entity.
• The NASAA item is temporally excluded. Whatever the 1999 enforcement action concerned, it cannot concern a company incorporated in 2016. It is also an item about an entity abbreviated "AIF", not "Infinitum Capital".
• Zero adverse-media coverage of the subject entity itself was located across the search that ran. That is consistent with an entity of low public profile, and also consistent with an entity with no public footprint at all (see the null OSINT return in Section 1).
• Time span covered: the returned results span 1999 to 2025. No date restriction was applied and no structured media database was queried.

Content-Integrity Check

No prompt-injection or scoring-manipulation attempt was identified in the untrusted content block. The FinStat menu text is site navigation, not a directive. No red flag on this axis.

Risk Implication

The Adverse Media subscore of 62/100 at 22.7% applied weight contributes 14.07 points to the composite — the second-largest contribution — on the basis of two items that a first-pass human triage disqualifies. This materially overstates conduct risk. See Section 11.

At the same time, the domain must not be recorded as a clean pass. Google Programmable Search is not an adverse-media screening tool: it applies no entity resolution, no structured taxonomy, no jurisdictional filtering and no negative-news source list. The correct compliance position is screen ran, no attributable adverse media identified, coverage quality low.

The Slovak homonym is a research hazard requiring permanent suppression logic, not a network finding. No shared officer, address or ownership links UK 10206158 to INFINITUM CAPITAL s.r.o. in this evidence set — see Section 9.

Assessment

No regulatory or enforcement action against INFINITUM CAPITAL LIMITED (10206158) was identified. No regulator, date, matter type, outcome or penalty amount is reported, because no such matter was returned. However, the screen that ran was not a regulator-register check, and a critical scoring anomaly sits in this domain.

Evidence

Critical Scoring Anomaly

The Regulatory & Enforcement domain reports zero adverse findings at every severity level, yet carries a subscore of 71/100 at an applied weight of 20.4%, contributing 14.48 points — the single largest contribution to the 37-point composite.

The supplied evidence does not explain this subscore. It cannot be derived from the domain's own inputs. Either the model is applying an undisclosed penalty (plausibly for the absence of a primary regulator-register check, which would be defensible but is not documented), or the subscore is erroneous. Either way, the composite is not reproducible from the evidence shown, and a risk committee should require re-derivation before relying on the figure. See Section 11.

The Primary-Source Gap

For an entity whose registered name signals investment or capital-markets activity, the absence of an FCA Financial Services Register check is a material control gap, not a clean result.

From this evidence it is not possible to state whether INFINITUM CAPITAL LIMITED is:

• authorised or registered by the FCA;
• an appointed representative;
• exempt;
• carrying on no regulated activity at all; or
• named on the FCA Warning List.

Under FSMA 2000 s.19 (general prohibition), carrying on a regulated activity in the UK without authorisation is a criminal offence. A firm onboarding a counterparty whose name implies investment activity is expected to establish its regulatory status. A Google search does not establish it.

Risk Implication

• NOT FOUND ≠ no enforcement history. The only sources that ran were general web searches. A regulatory action that was never indexed prominently, or that appears only on a regulator's own register, would not surface.
• The unqueried Companies House disqualified directors register leaves the fitness of BHATNAGAR, Dhruv (Section 2) unassessed.
• Required next steps: (1) FCA Register lookup by name and company number; (2) FCA Warning List lookup; (3) disqualified-directors register check on the confirmed director; (4) re-derivation of the 71/100 subscore against documented logic.

Assessment

The litigation domain returned 10 results: 3 adverse (all MEDIUM), 1 positive, 6 neutral. None of the three adverse items constitutes litigation involving INFINITUM CAPITAL LIMITED. Two are grammatical artefacts; one is an investment-round announcement misclassified because an unrelated headline containing the word "lawsuit" appeared adjacent in the snippet.

Court records were not searched directly. No court database, no insolvency register and no county court judgment register appears in the source ledger. All litigation evidence in this file is news-derived.

Adverse Items — Attribution Analysis

Key Findings

• Two of three adverse litigation hits are false positives generated by a full stop. The string "Ad infinitum. Capital" is not an entity name. These items are recorded as artefacts and should be suppressed permanently.
• The Ayar Labs item is not adverse and is not litigation. It records "Infinitum Capital" as a participant in a US$130m Series C financing round alongside Nautilus Venture Partners and Tyche Partners, per the publication. Whether that investor is company 10206158 is UNVERIFIED — the article does not supply a registration number or jurisdiction, and this evidence set contains nothing to link them. It is analysed further in Section 8 because, if resolved, it bears on financial profile rather than litigation.
• No pattern of repeat litigation, class action or insolvency proceeding was identified — and none could have been, since no court or insolvency register was queried.
• Jurisdiction, court, case type, parties, status and outcome are NOT FOUND for the subject entity, because no proceeding involving the subject was located.

Risk Implication

The Litigation subscore of 42/100 at 11.4% applied weight contributes 4.79 points to the composite on the basis of three non-attributable items. This overstates litigation risk for the subject.

Simultaneously, litigation risk is materially under-screened: UK court listings, the Insolvency Service register, CCJ records and the Gazette were not searched. Under MLR 2017 reg. 28(11), a firm must be able to demonstrate it understands the customer's circumstances; a news-only litigation screen does not support a finding that no proceedings exist.

Required next step: run a direct search of the Insolvency Service register, the London Gazette and available court listings against the entity name and company number, and against the confirmed director.

Assessment

Screen status: NOT RUN

No dedicated ESG data source was consulted. No ESG rating provider, modern-slavery register, environmental regulator database, employment tribunal record, whistleblower database or data-breach registry appears in the source ledger. ESG and conduct risk is therefore UNASSESSED, not clean.

Evidence

Governance Observations (from registry evidence only)

These are the only conduct-relevant observations the evidence supports, and they are governance points already made in Section 2:

1. 1.Control rests on an unverified self-declaration. The sole PSC entry (Shruti Luthra) is DECLARED, not independently verified. Transparency of control is therefore incomplete.
2. 2.Separation of the management and control layers. The confirmed director and the declared controller are different named individuals. This is lawful and common, but it means governance accountability is split across persons whose relationship is not documented in the evidence.
3. 3.No incomplete-filing or compliance-failure indicator was retrieved — because no filing history was retrieved at all. This is NOT FOUND, not a clean compliance record.

Risk Implication

ESG exposure cannot be sized because the entity's business activity is unknown (Section 1) and its financial scale is unknown (Section 8). A company with no established operations, no employees evidenced and no supply chain evidenced presents a low inherent ESG footprint on the available facts — but that conclusion is a function of missing data, not of positive evidence of good conduct.

Reference frameworks that would apply if operations were established (UN Global Compact, TCFD, CSRD, UK Modern Slavery Act 2015 s.54) cannot be applied without turnover figures — the Modern Slavery Act reporting threshold is turnover-based, and no turnover figure was retrieved.

ESG & Conduct is not a weighted factor in the risk model (see Section 11); it influences the composite only indirectly through Transparency Risk, which is scored 8/100. Firms with ESG-sensitive mandates should treat this domain as an open item rather than as a scored pass.

Assessment

No financial data of any kind was obtained for INFINITUM CAPITAL LIMITED. The FINANCIAL domain returned ten general web search results and zero primary financial records. This is a search-engine result, not a financial assessment. For a company incorporated in 2016 and still active as at 18 August 2026, this is a material due diligence deficiency.

Evidence

The One Correlation Worth Pursuing

The only evidence in the entire file touching financial activity is the Ayar Labs Series C announcement discussed in Section 7, which lists "Infinitum Capital" among the investors in a US$130m round reported on 27 April 2022 [Source: compoundsemiconductor.net, https://compoundsemiconductor.net/article/114667/AyarLabsRaises130MinSeriesC_Funding].

Identity is UNVERIFIED. The article supplies no registration number, jurisdiction or address. There are numerous entities worldwide using this trading name — the Slovak s.r.o. in Section 5 is proof of that.

The resolution matters because the two possible outcomes point in opposite directions:

• If the investor is company 10206158, the entity is an active venture-capital investor deploying institutional-scale capital, and source-of-funds/source-of-wealth enquiries become substantially more demanding — LP structure, capital commitments, custody arrangements and, critically, its FCA regulatory status (Section 6) all require examination.
• If it is not, the entity's financial substance remains entirely unevidenced.

This question cannot be left unresolved at onboarding. It is closed by obtaining the SIC code and filed accounts from Companies House — one lookup.

Red-Flag Screen

Assessed against the standard indicators:

• Negative net worth: cannot be assessed — no accounts retrieved.
• Rapid unexplained growth: cannot be assessed — no accounts retrieved.
• Opaque funding: partially indicated. No funding source, no financial statements, no operational footprint (OSINT null, Section 1), and a care-of registered office. This is not evidence of impropriety; it is evidence that the firm currently has no basis on which to form a view of source of funds.

Risk Implication

Under MLR 2017 reg. 28(11)(b)–(c), a firm must obtain information on the purpose and intended nature of the business relationship and conduct ongoing monitoring including scrutiny of transactions to ensure consistency with the firm's knowledge of the customer's business and risk profile. That knowledge does not currently exist. An annual monitoring cycle (per the model recommendation) applied to a customer whose expected activity profile is undefined is monitoring in name only.

Note that this deficiency reaches the composite score only weakly — Transparency Risk is scored 8/100 at 4.5% weight, contributing 0.36 points. That is a structural weakness of the model, discussed in Section 11.

Assessment

The subject is incorporated in the United Kingdom, a FATF member jurisdiction. No reference dataset — FATF, EU high-risk third country list, or Transparency International CPI — appears in the source ledger. Jurisdictional risk is therefore assessed on the registry facts and general knowledge of UK status only, and no CPI score or FATF list version can be cited from evidence.

Evidence

Cross-Border Signal — The Slovak Homonym

The only cross-border element in the file is INFINITUM CAPITAL s. r. o., a Slovak entity appearing on FinStat.sk (https://finstat.sk/56739036), discussed in Section 5.

There is no evidence linking UK company 10206158 to that entity. Specifically, the evidence set contains:

• no shared officer;
• no shared address;
• no shared ownership;
• no transactional or contractual link.

A shared trading name across two jurisdictions is a research hazard, not a network finding. It must not be scored as jurisdictional exposure to Slovakia unless and until a common natural person, address or ownership interest is demonstrated.

Key Findings

• The declared jurisdiction (GB) is user-provided but is corroborated by the Companies House registry record, which is authoritative. Jurisdiction confidence is therefore effectively VERIFIED, not merely asserted.
• Operating jurisdictions are unknown. The entity's registered office is a care-of professional address; nothing in the file establishes where, or whether, it trades. A UK incorporation does not evidence UK operations.
• The single foreign-jurisdiction data point in the file (Ayar Labs, a US company, Section 8) is unverified as to whether it concerns the subject.

Risk Implication

UK incorporation is, on its own, a low-risk jurisdictional starting point: the UK is a FATF member with a public beneficial ownership register. The residual jurisdictional risk in this file arises not from the country of incorporation but from the absence of any evidence of where the business actually operates — which prevents assessment of counterparty-country exposure, and is the same gap identified in Sections 1 and 8.

The Jurisdiction Risk subscore of 35/100 contributes 2.38 points to the composite. Given UK status, that figure appears conservative rather than understated, and is not the driver of the composite (see Section 11).

Scoring Model — As Supplied

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 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 ``

Applied weights sum to 100.0% and the arithmetic reproduces the supplied composite of 37/100 exactly. Weights were renormalised across the six domains that ran; the PEP domain was excluded from renormalisation and contributes zero.

What Actually Drives the Score

28.56 of the 37.11 points (77%) come from two domains — Adverse Media and Regulatory & Enforcement — whose subscores cannot be reconciled with their own evidence.

• Adverse Media (14.07 pts): built on two items that first-pass human triage disqualifies. One is a foreign homonym with no allegation attached; the other is chronologically impossible.
• Regulatory & Enforcement (14.48 pts): built on zero adverse findings. The evidence supplied provides no explanation for a subscore of 71/100. If the model is penalising the absence of a primary regulator-register check (a defensible position — see Section 6), that logic is undocumented and cannot be audited.

By contrast, the domain carrying the strongest genuine evidence — the clean sanctions screen — is correctly scored at 3/100 and is the only factor in the model whose value is fully supported.

Model Limitations — For Committee Attention

1. 1.The composite is not reproducible from the evidence shown. The arithmetic reproduces; the inputs do not. This distinction matters for audit and regulatory defensibility.
2. 2.The score is simultaneously overstated and understated. Overstated on conduct (false-positive adverse media and litigation). Understated on coverage (PEP unrun; FCA register unchecked; no financial data; no court records; no ESG source).
3. 3.Transparency Risk is weighted at 4.5% — the lowest of any factor. Yet it is the sole channel through which the file's most substantive deficiencies (unverified PSC, zero financial data, no business activity established) reach the score. At that weight, those deficiencies move the composite by fractions of a point. A structurally opaque file can score well on this model.
4. 4.PEP is excluded, not zero. The coverage statement is explicit. A PEP match would require full re-derivation.

Assessed Position

• Model band: Medium-Low (37/100)
• Analyst-assessed risk level: MEDIUM
• Confidence: LOW

The uplift from the model band reflects coverage risk, not conduct risk. There is no verified adverse finding against this entity anywhere in the file. There is also insufficient evidence to characterise it as low risk with confidence, because an entire mandatory screening domain did not execute and the entity's business activity, financial substance and regulatory status are all unestablished.

Recommendation

Standard CDD — CONDITIONAL. No final onboarding decision should be recorded until the mandatory gap-closure actions below are completed.

Rationale

Why not EDD: MLR 2017 reg. 33 requires EDD in defined circumstances — none is met on this evidence. No sanctions match (Section 3), no verified adverse media (Section 5), no regulatory action (Section 6), no litigation involving the subject (Section 7), no high-risk third-country nexus (Section 9). The five adverse items in the file are name collisions, and elevating a customer to EDD on the basis of demonstrable false positives would be both wrong and unfair to the individuals named.

Why not Standard CDD unconditionally: the file cannot currently evidence compliance with three distinct obligations —

• reg. 35 — no PEP determination has been made for either named person (Section 4);
• reg. 28(4)(a) — beneficial ownership rests on an unverified self-declaration (Section 2);
• reg. 28(11) — the nature of the customer's business is not established; no SIC code, no accounts, no operational footprint (Sections 1 and 8).

Why not rejection: no evidence supports it. Absence of information is not adverse information. Rejection on the basis of an incomplete screening file would be a de-risking decision, not a risk-based one, and is expressly not recommended.

Outstanding Information Gaps

Required Actions

1. 1.Run PEP/RCA screening on BHATNAGAR, Dhruv and Shruti Luthra. Obtain DOB, nationality and residence first so the screen is discriminating rather than name-only. This must complete before onboarding.
2. 2.Query the FCA Financial Services Register and FCA Warning List directly for "Infinitum Capital Limited" and company number 10206158. Record the authorisation status on file. Given the trading name, this is not optional.
3. 3.Pull the full Companies House record: SIC code, filing history, latest accounts, confirmation statement date, dormancy/exemption status, and the complete PSC entry with nature-of-control statement.
4. 4.Verify the PSC independently of the self-filed register entry using identity documentation or equivalent evidence.
5. 5.Resolve the Ayar Labs question. If the entity is an active venture-capital investor, escalate for a source-of-funds review and re-assess whether reg. 33 EDD is engaged.
6. 6.Search UK court, insolvency, Gazette and CCJ records directly against the entity and the confirmed director.
7. 7.Clear the five false positives on the file with a documented rationale, and implement suppression so they do not re-surface at each review cycle as apparent adverse hits.
8. 8.Re-derive the composite score once PEP has run and the false positives are cleared. Flag the Regulatory & Enforcement subscore anomaly (71/100 on zero findings) to the model owner.

Trigger Events for Immediate Review

• Any PEP or sanctions match arising on either named individual
• Change of director, PSC, or registered office
• Confirmation that the entity carries on regulated investment activity, or appearance on the FCA Warning List
• Filing of a strike-off, insolvency or overdue-accounts notice at Companies House
• Any demonstrated link (shared officer, address or ownership) between company 10206158 and INFINITUM CAPITAL s.r.o. (Slovakia)
• Transaction activity inconsistent with the (currently undefined) expected profile
• Confirmation that the entity was an investor in the Ayar Labs Series C round

Monitoring Caveat

Annual monitoring is only meaningful once an expected activity profile exists. At present none does (Section 8). Until the SIC code and accounts are obtained, ongoing monitoring under reg. 28(11)(b) cannot function as designed, and the annual cycle should be treated as a minimum rather than as an adequate control.

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. All screening results are point-in-time as at that date.

Methodology

1. 1.Registry-first identity resolution. The Companies House record was treated as the authoritative anchor. All other evidence was tested for attachment to company number 10206158 specifically, not to the string "Infinitum Capital".
2. 2.Attribution triage of every adverse item. Each of the five adverse hits was assessed against three tests: (a) does it name a legal person distinct from the subject? (b) is it chronologically possible relative to the 31 May 2016 incorporation date? (c) is the match an entity reference or a linguistic artefact? All five failed at least one test.
3. 3.Evidence-status tagging. Every material claim is tagged VERIFIED / CORROBORATED / UNVERIFIED / NOT FOUND / NOT RUN / SKIPPED. Absence of data has nowhere been converted into a clean result.
4. 4.Source-ledger reconciliation. Domain findings were reconciled against what the ledger records as having actually executed. Where a subscore could not be derived from its own domain evidence (Regulatory & Enforcement, 71/100 on zero findings), that is reported as a model anomaly rather than restated as a finding.
5. 5.Independent re-derivation of the composite. The weighted arithmetic was recomputed from the supplied subscores and applied weights and reproduces 37.11 → 37/100 exactly. Reproducibility of the arithmetic is distinguished from reproducibility of the inputs.
6. 6.Content-integrity control. All third-party retrieved content was treated as data. It was inspected for embedded instructions or scoring-manipulation attempts. None was found; the only directive-resembling text is FinStat site-navigation boilerplate.
7. 7.Critical review of the pre-synthesis brief. The brief's core conclusion — that the adverse hits are name collisions — is verified against the evidence and adopted. Two brief elements were rejected: (a) an inference of national origin from a personal name, which is unsupported by any retrieved data and has been excluded; (b) the statement that Companies House "would hold nine years of filings" — as at the 18 August 2026 report date the company is approximately ten years old, and in any event no filing history was retrieved, so the count is immaterial.

Limitations

• PEP screening did not run. The single largest coverage gap. No PEP, RCA or HIO determination exists for either named individual.
• No primary regulator-register check. FCA Register and Warning List were not queried, despite the entity's trading name.
• No primary financial data. No accounts, turnover, assets or funding information. Source of funds and source of wealth are entirely unassessed.
• No court records. All litigation coverage derives from general web search, two hits of which are Facebook posts.
• Beneficial ownership unverified. The sole PSC entry is self-declared. No percentage band or nature-of-control statement was retrieved.
• Identity resolution incomplete beyond the registry. At least one homonymous foreign entity exists (INFINITUM CAPITAL s.r.o., Slovakia). The Ayar Labs investor identity remains unresolved.
• No ESG source consulted.
• No FATF or TI CPI reference data consulted. No CPI figure is cited anywhere in this report because none was retrieved.
• Search-tool quality. Four of five non-registry domains were screened using a general web search engine, which performs no entity resolution and produced a 100% false-positive rate on adverse items in this file.

Legal & Regulatory Framework

UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 — reg. 5 (beneficial owner), reg. 27–28 (CDD), reg. 33 (EDD), reg. 35 (PEPs); FCA SYSC 6.3 and SYSC 12.1; FSMA 2000 s.19; Sanctions and Anti-Money Laundering Act 2018; Companies Act 2006 Part 21A (PSC register); FATF Recommendations 10, 12, 24; EU 5AMLD Article 30; EU 6AMLD; UK Modern Slavery Act 2015 s.54.

Confidence

Overall confidence: LOW.

The principal reasons for the low overall confidence are: (1) an entire mandatory screening domain did not execute; (2) the two largest contributors to the composite score cannot be reconciled with their own evidence; (3) the entity's business activity, financial substance and regulatory status are all unestablished after approximately ten years of corporate existence. Confidence in the absence of verified adverse findings is reasonable; confidence in the completeness of the assessment is not.