EMPASS LAW LIMITED

Assessment

Entity identity is VERIFIED against an authoritative registry. The subject resolves to a single, active, UK-incorporated private limited company. Identity risk is low; the registry record, the SRA register record and a third-party lender panel listing are mutually consistent on name and address.

Evidence

Key Findings

• Jurisdiction confidence: the GB jurisdiction was user-provided but is independently corroborated by the Companies House record. No jurisdiction ambiguity remains.
• Business activity: the entity presents as a solicitors' practice. This is supported by the SRA register entry, the ReviewSolicitors profile and inclusion on The Cumberland's panel of eligible solicitors. The SIC code(s) filed at Companies House were not retrieved, so the registry-declared activity is unconfirmed.
• Date anomaly: three search results relating to the SRA register carry a date stamp of 2019-10-08, approximately two years before incorporation. This is most consistent with a search-engine indexing artefact and should not be read as evidence of a predecessor entity or an earlier regulatory event.

Gaps

• Not retrieved: SIC code, accounting reference date, filing history, previous names, mortgage/charges register, and any registered-office change history.
• Not retrieved: whether 13 Hanover Square, W1S 1HN is a trading premises or a serviced/registered-office address shared with other entities. No conclusion is drawn either way; the address itself is not treated as a risk indicator on the current evidence.

Risk Implication

Identity is sufficiently established for CDD purposes under MLR 2017 reg. 28(2) (identification of the customer from a reliable, independent source). The outstanding items above are file-completeness gaps rather than identity risk. The absence of filing-history and charges data limits the financial analysis in Section 8.

Assessment

Control is partially established. Two directors are CONFIRMED from the Companies House officers register. Two persons with significant control are DECLARED only — filed by the company and not independently verified by the registrar. The corporate PSC does not resolve to an ultimate natural person on the evidence retrieved. This is the principal transparency gap on the file.

Officers and Controllers

The 25% Threshold

Under the UK PSC regime (Companies Act 2006 Part 21A) and MLR 2017 reg. 5, a person is a beneficial owner / registrable person where they directly or indirectly hold more than 25% of the shares or voting rights, hold the right to appoint or remove a majority of the board, or otherwise exercise significant influence or control. The specific nature-of-control statements for both declared PSCs — that is, which of these limbs applies and at what banding (over 25% up to 50%, over 50% up to 75%, or over 75%) — were NOT retrieved. Without them the firm cannot demonstrate under reg. 28(4)(b) that it understands the ownership and control structure.

Corporate Chain

• Empass Holdings Limited is declared as a corporate PSC. Its company registration number, jurisdiction of incorporation, own officers and own PSCs were not retrieved.
• Consequently the chain terminates at a corporate layer. The ultimate natural person(s) behind Empass Holdings Limited are NOT ESTABLISHED, notwithstanding that Mr Rohit Dindayal Fogla is separately declared as an individual PSC (which suggests, but does not evidence, that he controls the holding company).
• No evidence was retrieved of trusts, nominee arrangements, bearer instruments or non-UK holding layers. Their absence from the retrieved data is NOT FOUND, not a confirmed negative.

Relevant Third Parties Not on the Register

Solicitor Ardeshir Matini, named in the trade-press item discussed in Sections 5 and 6, does not appear on the officers or PSC data retrieved. Whether he is or was an employee, consultant, member, manager or SRA-recognised individual of the practice is unresolved. Note that SRA regulatory control (compliance officers, managers, authorised persons) does not map onto the Companies House officers register, so a person may be materially connected to a law firm without appearing in either dataset retrieved here.

Risk Implication

A declared-but-unverified corporate control layer is a standing transparency risk under FATF Recommendation 24, EU 5AMLD Article 30 and MLR 2017 reg. 28(4). The Transparency Risk factor was scored 8/100 in the model (Section 11), which reflects the presence of a populated PSC register rather than verification of its contents. In this analyst's view that factor is generous relative to the unresolved corporate chain, and the gap should be closed by document request rather than left to the score.

Assessment

Screen status: RAN — genuinely no findings. This is one of the few unambiguously clean signals in this report.

Evidence

Limitations

• The evidence does not state whether the confirmed directors (Fogla, Rohit Dindayal; Gautam, Pankaj) or the declared PSCs (Empass Holdings Limited; Mr Rohit Dindayal Fogla) were screened individually, or whether only the corporate entity was submitted. This must be confirmed. Under MLR 2017 and the Sanctions and Anti-Money Laundering Act 2018, screening obligations extend to beneficial owners and controllers, not only the contracting entity.
• The lists named are OFAC, OFSI and UN. No confirmation was supplied that the EU Consolidated List, national lists of other operating jurisdictions, or UK/US export-control and debarment lists were included.
• No screening thresholds, transliteration handling or fuzzy-match tolerance were disclosed by the provider.

Cross-Reference

The unresolved corporate ownership layer in Section 2 materially limits this screen: a sanctions result on the named entity cannot speak to any undisclosed controller sitting above Empass Holdings Limited. A clean entity-level result and an unverified ownership chain are not the same assurance.

Risk Implication

No sanctions exposure identified as at the screening date. Sanctions status is dynamic; the clean result is a point-in-time statement and supports ongoing-monitoring placement rather than a permanent clearance.

Assessment

Screen status: NOT RUN

No PEP screening was performed. 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.

What This Means

• No determination has been made as to whether the entity, its directors, its declared PSCs or their family members and known close associates hold or have held prominent public functions.
• No PEP, RCA or HIO status can be asserted in either direction. The correct status on this file is UNDETERMINED, not "not a PEP".
• No political position, jurisdiction of office or period of office can be reported, because no dataset was queried.
• Role-keyword inference is expressly not used. Nothing in the Companies House or open-source evidence is treated as a proxy for a PEP determination.

Regulatory Position

Where a PEP relationship is established, MLR 2017 reg. 35 requires senior management approval, establishment of source of wealth and source of funds, and enhanced ongoing monitoring. None of those steps can be triggered or ruled out on the current evidence.

Required Next Step

Run PEP/RCA screening against, at minimum:

1. 1.FOGLA, Rohit Dindayal (director; declared individual PSC)
2. 2.GAUTAM, Pankaj (director)
3. 3.Empass Holdings Limited and, once identified, its ultimate natural person controllers (see Section 2)

Risk Implication

This is the single largest coverage gap in the assessment. The composite of 39/100 in Section 11 is computed across six domains only; a PEP hit on any of the named individuals would change both the CDD level and the monitoring frequency recommended in Section 12. No onboarding sign-off should record this file as screened until this is closed.

Assessment

The automated adverse-media classification is unreliable for this subject and materially overstates reputational risk. Ten results were returned (3 classified adverse, 1 positive, 6 neutral; severity: 0 critical, 3 high, 0 medium, 0 low). On analyst review, none of the three "HIGH" items evidences misconduct, allegation or investigation involving EMPASS LAW LIMITED.

Item-by-Item Review

Critical Handling Instruction on Item 3

The Daily Mail sitemap snippet contains the fragment "charged with three counts of sexual exploitation of a minor". There is no evidence whatsoever linking that text, or the referenced article, to EMPASS LAW LIMITED or to any individual associated with it. The match arises solely because a sitemap file lists thousands of article URLs and one contains the digit string 13778949. This item:

• must not be recorded on the customer file as an adverse media hit;
• must not be included in any SAR, escalation memo or client-facing summary;
• should be suppressed at source in the screening tool to prevent recurrence.

Recording it would create defamation exposure and would breach UK GDPR Article 5(1)(d) (accuracy) in respect of any identified individual.

Genuine Reputational Signal

The one item of real reputational substance was returned by the Regulatory search rather than the adverse-media search: the solicitornews.co.uk report of 29 September 2025 concerning SRA restrictions on solicitor Ardeshir Matini, stated to have been linked to Empass Law Limited. This is analysed in Section 6. It is an allegation/regulatory-restriction report against an individual, reported by a trade publication — not a court finding, not a conviction, and not a determination against the subject entity.

Coverage and Limitations

• Search tool: Google Programmable Search only. No licensed adverse-media database (e.g. structured negative-news screening with entity resolution) was used.
• Time span: not constrained or reported; two of three adverse items are undated, which prevents any recency-weighted assessment.
• Language: English-language web results only, so far as can be determined.
• AML/CTF relevance: no allegation of money laundering, terrorist financing, fraud, bribery, sanctions evasion or client-account misappropriation involving the subject entity was identified in any retrieved item.

Risk Implication

The Adverse Media factor scored 66/100 (Section 11), contributing ~15 points of the 39-point composite. On the evidence reviewed, that score reflects classifier error, not reputational exposure. The correct compliance response is to re-run the screen through a properly entity-resolved provider, not to accept the elevated score at face value — and equally, not to discount the genuine solicitornews.co.uk item because the surrounding results were noise.

Assessment

The entity is recorded on the Solicitors Regulation Authority register with no published regulatory decisions against the firm. Separately, a trade publication reports SRA practice restrictions on an individual solicitor said to have been linked to the firm. These two facts must be kept distinct.

Evidence

Analytical Distinctions

1. 1.Individual ≠ firm. SRA practice restrictions attach to a named solicitor. The retrieved SRA firm-level record shows no published decisions against EMPASS LAW LIMITED. There is no evidence the SRA has taken action against the entity.
2. 2.Restriction ≠ finding of dishonesty ≠ SDT conviction. SRA practice conditions/restrictions may be imposed on regulatory-objective grounds and are not, of themselves, a determination of misconduct by a tribunal. The evidence does not disclose the grounds.
3. 3."Linked to" is undefined. The publication's phrasing does not establish employment, partnership, management, ownership or a compliance-officer role. Mr Matini appears nowhere in the Companies House officers or PSC data retrieved (Section 2).
4. 4.Temporality. The article is dated 29 September 2025 and refers to the position "by the date of publication of the most recent outcome". Whether any association subsists as at the report date of 27 August 2026 is not established.

Date Anomaly

The SRA register result is date-stamped 2019-10-08 in the Regulatory, Litigation and Financial search outputs — before the company's incorporation on 2 December 2021. This is almost certainly search-index metadata rather than an event date. It also means the same single URL was counted as an adverse item in three separate risk domains, inflating Regulatory (62), Litigation (66) and Financial scores from what is in substance one neutral-to-favourable primary-source page.

Coverage Gaps

• Not queried directly: SRA register API/live lookup; SRA published decisions and disciplinary outcomes database; Solicitors Disciplinary Tribunal judgments; SRA intervention notices; the Legal Ombudsman.
• Not queried: FCA Register (the entity is not indicated to be FCA-authorised, but this was not tested), Information Commissioner's Office enforcement, HMRC AML supervision.
• Not established: whether the firm holds SRA authorisation to conduct reserved legal activities on a current basis, its compliance-officer appointments (COLP/COFA), or its own AML supervisory arrangements.

Risk Implication

A solicitors' practice is a supervised person under MLR 2017 and typically operates a client account — a recognised money-laundering vulnerability in the UK National Risk Assessment context. Regulatory restrictions on any individual practising within such a firm are therefore relevant to counterparty risk even where the firm itself is unblemished. The correct action is verification against the SRA's own decision records, not escalation on the basis of a single trade-press snippet. Cross-refer to Section 5 (reputational treatment) and Section 12 (required actions).

Assessment

No litigation involving EMPASS LAW LIMITED was identified. However, this is a NOT FOUND result derived from a general web search — court records were not searched directly. It must not be recorded as "no litigation".

Evidence

The snippet's reference to "Solicitors Disciplinary Tribunal" and "Intervention into a practice" is standard SRA website navigation, not an indication that either has occurred in relation to this firm. The same page separately records "No decisions published" (Section 6).

What Was Not Searched

• Not searched: HMCTS / Ministry of Justice Register of Judgments, Orders and Fines; BAILII and The National Archives Find Case Law; Business & Property Courts and County Court listings; Employment Tribunal decisions database.
• Not searched: The Insolvency Service register, London Gazette notices, winding-up petitions.
• Not searched: SRA intervention notices and SDT judgment archive (relevant given Section 6).
• Not searched: any non-UK court records.

Pattern Analysis

No pattern of repeat litigation, class action or insolvency activity can be asserted or excluded, because the underlying datasets were never queried. Given the entity was incorporated in December 2021, a short operating history also limits the volume of any litigation record that would exist.

Risk Implication

The Litigation factor scored 66/100 and contributed approximately 7.5 points to the composite (Section 11), yet the sole item driving it is a false positive. The score is not supported by the evidence and should be treated as an artefact. Conversely, the genuine absence of assurance — no direct court-record search — is a coverage gap to be closed at the next review or sooner if the SRA matter in Section 6 is confirmed as material.

Assessment

No financial information was obtained. This is a material due-diligence deficiency, not a neutral finding.

Evidence Position

Red-Flag Screen

The standard financial red flags cannot be tested against the available evidence:

• Negative net worth — untested; no balance sheet retrieved.
• Rapid unexplained growth — untested; no multi-year figures retrieved.
• Opaque funding — partially indicated but unresolved. The corporate PSC layer (Empass Holdings Limited, Section 2) is unverified, so the source of the company's capital cannot be traced to an ultimate natural person.

None of these red flags is asserted. Each is recorded as untested.

Sector-Specific Considerations

As an SRA-regulated solicitors' practice, the entity would ordinarily:

1. 1.operate a client account holding third-party funds, which is the primary AML-relevant financial feature of such a firm;
2. 2.be subject to the SRA Accounts Rules, including an annual accountant's report obligation where applicable;
3. 3.be a relevant person in its own right under MLR 2017 in respect of independent legal professional activities.

None of these has been evidenced. Client-account arrangements, the identity of the firm's banking counterparties, and expected transaction volumes are all unknown.

Required Documentation

1. 1.Most recent filed statutory accounts and, if a small-company exemption applies, management accounts.
2. 2.Confirmation of client-account banking arrangements and expected activity profile.
3. 3.Confirmation of the firm's own AML supervisor, MLRO/MLCO appointments and last independent AML audit.
4. 4.Source-of-funds narrative for the initial and any subsequent capitalisation, tied to the verified ownership chain in Section 2.

Risk Implication

MLR 2017 reg. 28(11)(a) requires ongoing monitoring to include scrutiny of transactions to ensure consistency with the firm's knowledge of the customer, its business and risk profile. That knowledge does not presently exist. No transaction-monitoring baseline can be set. This gap does not by itself justify refusal, but it does prevent a complete risk-based assessment and must be closed before material exposure is taken.

Assessment

All identified footprint is in the United Kingdom. No offshore, high-risk or non-cooperative jurisdiction exposure was identified in the evidence retrieved — but note that no country-risk reference dataset was queried in this run.

Evidence

Reference Datasets — Status

Screen status: NOT RUN for country-risk reference data.

No FATF list, EU High-Risk Third Country list or Transparency International CPI dataset was queried as part of this assessment. The source ledger contains no country-risk provider. Accordingly:

• FATF status: no FATF grey-list or black-list check was performed in this run, and no CPI score is reported, because none was retrieved. Fabricating a score or a list position would be a reporting integrity failure.
• The Jurisdiction Risk factor score of 35/100 in the model (Section 11) is a model-assigned baseline for the GB jurisdiction. It is not derived from a dataset queried here and should be treated as an assumption to be validated at the next review.

Analytical Points

• The United Kingdom is a FATF member and a comprehensively regulated jurisdiction, which limits inherent country risk. That said, the UK legal services sector is consistently identified in UK national risk assessment material as carrying elevated inherent ML risk, particularly through client accounts, property transactions and company formation. This is sectoral risk, not country risk, and it is not evidenced against this specific firm.
• Jurisdiction of the holding company is the live gap. Until Empass Holdings Limited's jurisdiction of incorporation is confirmed (Section 2), the assertion that the group is wholly UK-based is unverified. If that entity, or any layer above it, sits offshore, this section's conclusion changes.

Risk Implication

On present evidence, geographic risk is low and contributes only ~2.4 points to the composite (Section 11). The conclusion is contingent on resolving the corporate chain identified in Section 2; it should not be treated as settled until that is done.

Assessment

Screen status: NOT RUN

No dedicated ESG data source was consulted. No ESG ratings provider, modern-slavery statement registry, ICO breach register, environmental regulator database or labour-tribunal dataset appears in the source ledger. The observations below derive solely from general web search results and the registry record.

Domain-by-Domain Position

Conduct Risk Commentary

The only conduct-relevant signal in the evidence set is the individual-level SRA restriction reported by solicitornews.co.uk on 29 September 2025 (Section 6). For a professional services firm, conduct and governance risk concentrates in:

1. 1.Supervision of fee-earners — directly engaged by any restriction on a practising solicitor associated with the firm;
2. 2.Client money handling under the SRA Accounts Rules — unevidenced (Section 8);
3. 3.Client confidentiality and data security — unevidenced.

None of these has been tested. The firm's own SRA record shows no published decisions (Section 6), which is a mitigating governance data point at entity level.

Risk Implication

ESG is not a weighted factor in the composite scoring model (Section 11) and contributes nothing to the 39/100 score. It is recorded here for completeness and because governance opacity — the unverified control chain — is the same underlying issue that drives the Transparency Risk factor. For a counterparty of this type and apparent size, absence of ESG data is a proportionate gap rather than a barrier, but the ICO breach register and SRA supervision position should be checked if the relationship involves handling client-derived funds or personal data.

Composite Result

Composite score: 39/100 — Medium-Low band. Coverage: PARTIAL. Reported risk level: MEDIUM. Confidence: MEDIUM.

Scoring Table

Applied weights are the renormalised figures supplied in the risk block (34.1 + 22.7 + 20.4 + 11.4 + 6.8 + 4.5 = 99.9%, rounding to 100%), redistributed across the six domains that actually ran.

Calculation

Composite Score = Σ(Factor Score × Applied Weight)

• Sanctions & Watchlists: 3 × 0.341 = 1.023
• Adverse Media: 66 × 0.227 = 14.982
• Regulatory & Enforcement: 62 × 0.204 = 12.648
• Litigation: 66 × 0.114 = 7.524
• Jurisdiction Risk: 35 × 0.068 = 2.380
• Transparency Risk: 8 × 0.045 = 0.360
• Politically Exposed Persons: not scored — screen did not run; contributes 0 and carries no weight

Total = 1.023 + 14.982 + 12.648 + 7.524 + 2.380 + 0.360 = 38.917 ≈ 39/100

What Actually Drives the Score

Approximately 35 of the 39 points come from the Adverse Media, Regulatory and Litigation domains combined. On analyst review:

• Adverse Media (15.0 pts) — driven entirely by false positives. Not evidentially supported.
• Litigation (7.5 pts) — driven by menu text on a regulator's website. Not evidentially supported.
• Regulatory (12.6 pts) — partially supported. One of the two items (solicitornews.co.uk, 29 Sep 2025) is a real, if unverified and individual-level, signal. The other is a favourable primary-source record.

Note also that the same single SRA URL was scored as an adverse item across three separate domains (Regulatory, Litigation, Financial), compounding its weight.

Two Offsetting Distortions

1. 1.Upward distortion: keyword-collision false positives inflate the composite. A cleaned score would likely fall into the Low band.
2. 2.Downward distortion: the composite omits PEP entirely and is not informed by any financial data (Section 8) or verified ownership chain (Section 2). It therefore reflects less than the full risk surface.

Because these pull in opposite directions and neither can be quantified on current evidence, 39/100 is retained as the reported figure, and the confidence rating is held at MEDIUM rather than raised. The score must not be presented to a committee or regulator as a complete assessment.

Band Consistency

A composite of 39 sits in the Medium-Low band. Reported as MEDIUM for the purposes of the risk-level field, consistent with the model output and with the outstanding PEP gap. Nothing in the evidence supports a HIGH or CRITICAL rating; nothing in the evidence yet justifies a LOW rating while the PEP screen remains unrun.

Recommendation

Standard CDD (MLR 2017 reg. 28), with three mandatory information requirements to be satisfied before final onboarding sign-off. Enhanced Due Diligence is not triggered on the current evidence. Manual compliance review is required before the file is closed, because the automated adverse-media output cannot be relied upon and one regulatory matter requires human verification.

This aligns with the model output (CDD recommendation: Standard CDD; EDD required: NO; Monitoring: ANNUAL), with the qualification that a Standard CDD conclusion cannot properly be recorded until the PEP determination is made.

Rationale

• No sanctions exposure — genuine clean result across OFAC/OFSI/UN (Section 3).
• No enforcement action against the entity — SRA record shows "No decisions published" (Section 6).
• Identity fully verified against Companies House; address independently corroborated (Section 1).
• The elevated media and litigation scores are artefacts, not exposure (Sections 5 and 7).
• But: PEP is undetermined, financials are absent, ownership is declared-only, and one individual-level SRA matter is unresolved.

The balance is a low-to-medium risk relationship with a completeness deficit, not a risk finding. Refusal is not supported by the evidence.

Outstanding Information Gaps

Required Actions

1. 1.Run PEP/RCA screening on FOGLA, Rohit Dindayal; GAUTAM, Pankaj; and the ultimate controllers of Empass Holdings Limited. Blocking item — no sign-off until complete.
2. 2.Verify beneficial ownership by obtaining the company registration number, jurisdiction, officers and PSCs of Empass Holdings Limited, plus nature-of-control percentages for both declared PSCs, and reconcile to the >25% threshold.
3. 3.Query the SRA register directly (not via search engine) for: current authorisation status of SRA number 835349; the firm's compliance officers; and any published decision concerning Ardeshir Matini, including its date, terms, current status and the role in which he was associated with the firm.
4. 4.Request financial documentation — latest filed accounts, client-account banking arrangements, expected transaction profile, and a source-of-funds narrative for capitalisation.
5. 5.Suppress the Daily Mail sitemap false positive in the screening tool and record on file that it was reviewed and rejected as a numeric collision on registration number 13778949 (Section 5). Ensure it does not propagate to any escalation, SAR or client-facing document.
6. 6.Record the manual review conclusion that the Adverse Media (66) and Litigation (66) domain scores are unsupported by the underlying items, so that the 39/100 composite is not misread by downstream reviewers.

Trigger Events for Immediate Review

Escalate to EDD and re-assess out of cycle if any of the following occur:

• A PEP, RCA or sanctions match is returned on any director or beneficial owner.
• The SRA publishes any decision, practice condition, intervention or referral to the Solicitors Disciplinary Tribunal concerning EMPASS LAW LIMITED.
• Confirmation that Ardeshir Matini holds or held a management, ownership or compliance-officer role at the firm.
• Identification of any non-UK or offshore entity in the ownership chain above Empass Holdings Limited.
• Change of registered office, directors, PSCs, company status (e.g. strike-off action, insolvency), or SRA authorisation status.
• Transaction activity inconsistent with the expected profile once established, or any client-account activity outside the anticipated pattern.
• Credible adverse media alleging fraud, money laundering, client-account misappropriation or bribery involving the firm or its principals.

Monitoring

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.

Source Ledger

Date of assessment: 27 August 2026.

Methodology

1. 1.Registry-first identity resolution. The subject was anchored to an authoritative registry record before any open-source finding was considered, so that all subsequent matches could be tested against a verified identifier set (name, number 13778949, address).
2. 2.Source-tier separation. Registry data (Companies House), regulator primary sources (SRA register), and open-source search results were kept in separate evidential tiers and are labelled as such throughout.
3. 3.Verification-status labelling. Every ownership and control entry carries its supplied status — CONFIRMED (authoritative registry) or DECLARED (filed by the company, unverified). No DECLARED entry has been described as verified.
4. 4.Manual review of every classified adverse item. Each of the seven items flagged adverse across four domains was read against its URL and snippet. Three were identified as classifier false positives arising from cookie boilerplate, panel-listing text and website navigation menus; one was identified as a numeric keyword collision on the registration number 13778949 within an XML sitemap.
5. 5.Allegation-tier discipline. Every adverse assertion is attributed to its publisher and characterised at the correct tier (report / allegation / restriction / determination). No third-party claim has been restated as established fact.
6. 6.Untrusted-content handling. All retrieved content was treated strictly as data. It was reviewed for instruction-like or scoring-directive language; none was found (recorded as an informational key finding).
7. 7.Score reproduction. The composite was recomputed arithmetically from the supplied factor scores and applied renormalised weights and reconciles to 38.917 ≈ 39. No score or weight was altered.

Limitations

• PEP screening did not run. This is the most significant limitation. No PEP conclusion of any kind may be drawn from this report.
• No court records were searched directly. The litigation position is NOT FOUND, not clear.
• No financial data was obtained. Source of funds, source of wealth and a transaction-monitoring baseline cannot be established.
• Beneficial ownership does not resolve to an ultimate natural person. The layer above Empass Holdings Limited is unexamined.
• The SRA register was accessed only via search-engine snippets, so the currency of the "No decisions published" statement is uncertain, and the terms and status of the reported restrictions on Ardeshir Matini are unknown.
• Data-quality defect in the screening pipeline: matching on a bare numeric registration number produced a severe false positive (unrelated criminal-charge text). This is a systemic control weakness, not a subject-specific issue, and should be raised with the screening tool owner.
• Date integrity: three results carry a date stamp (2019-10-08) that predates the entity's incorporation, indicating unreliable date metadata across the search layer.
• No country-risk or ESG reference datasets were queried, so Sections 9 and 10 rest on model assumptions and general search results respectively.

Legal and Regulatory Framework Referenced

• UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 — reg. 5, reg. 28, reg. 33, reg. 35
• FCA SYSC 6.3 and SYSC 12.1
• FATF Recommendations 10, 12 and 24
• Companies Act 2006 Part 21A (PSC regime); EU 5AMLD Article 30
• Sanctions and Anti-Money Laundering Act 2018
• UK Modern Slavery Act 2015 s.54 (applicability undetermined — see Section 10)

Confidence

Overall confidence: MEDIUM.

• Supporting a higher rating: identity is fully verified against an authoritative registry and corroborated by two independent sources; the sanctions screen genuinely executed and returned nothing.
• Constraining the rating: one mandatory screen (PEP) did not run; beneficial ownership is declared-only and unresolved; no financial data exists on file; the adverse-media and litigation classifications are demonstrably unreliable; and the single genuine regulatory signal is an unverified third-party report about an individual whose relationship to the firm is undefined.

Confidence cannot be raised above MEDIUM until items 1–3 of the Required Actions in Section 12 are completed.