Beneficial owners
Segments
Parse alert and load policy
3sRule TM-RND-003 resolved to typology "Round-amount patterning". Loaded the GB policy pack and the institution's escalation matrix.
Intake · 1 records
Retrieve KYC and relationship history
11sPulled the customer file, 1 beneficial-owner record, prior dispositions and the current risk rating.
KYC retrieval · 15 records
Reconstruct transaction history
27sAnalysed 3 alerted transactions against a trailing twelve-month baseline; tested for threshold proximity, velocity, round-value patterning and pass-through.
Transaction analysis · 343 records
Expand counterparty network to 1 hop
34sResolved 1 counterparties and tested for shared identifiers, device overlap, circular flow and undisclosed common control.
Counterparty network · 19 records
Screen subject and counterparties
19sScreened against consolidated sanctions lists, the global PEP register and internal watchlists; applied the institution's discriminator rules to each candidate.
Sanctions & PEP · 3 records
Adverse media sweep
22sSearched 42 languages across licensed and open sources, deduplicated by event and tested each candidate for homonym risk.
Adverse media · 1,840 records
Weigh evidence and reach disposition
16sAggregated 5 weighted findings; suspicion score 0.00 against the institution's thresholds.
Risk reasoning · 5 records
Draft regulator-grade narrative
14sComposed the six-part narrative with a source citation on every asserted fact.
Narrative drafting · 5 records
Self-check against the QA rubric
9sVerified every narrative assertion resolves to a retrieved record, checked policy citations and tested the disposition against the escalation matrix.
Self-QA · 5 records
Transactions carry a consistent, verifiable economic purpose
3 of 3 transactions reference an identifiable instrument — Catering contract Q3.
Payment reference fields
Counterparties corroborated by documentation already on file
1 counterparty is evidenced in the customer file: Contract on file since 2024.
Customer document store
Activity consistent with declared expectation
Alerted volume 27,000 GBP sits within the declared monthly expectation of 30,000 GBP recorded for this relationship (independent coffee shop).
KYC profile CUS-118840
Screening alert discounted on identified discriminators
Naylor (fuzzy, 0.71) discounted: DOB differs by 14 years; Listed entity resident in a different jurisdiction; No shared identifiers.
OFAC SDN + Consolidated, UN, EU, UK OFSI
Established relationship with a stable alerting history
7-year relationship with 1 alert in the trailing twelve months, all previously dispositioned without a filing.
Case management history
Subject
Grover Lane Café Limited (CUS-118840) is a business customer of the institution since January 14, 2020, resident in Bristol, GB and recorded as independent coffee shop. The relationship carries a low inherent risk rating, last reviewed April 8, 2026. Declared source of funds is trading receipts, with an expected monthly throughput of 30,000 GBP. Identity was verified on January 14, 2020 by companies house + documentary.
Activity under review
Alert ALT-2026-88088 was generated by rule TM-RND-003 — repeated round-value credits inconsistent with declared turnover — covering 3 transactions totalling 27,000 GBP through the business banking channel between August 27, 2026 to August 25, 2026. 3 inbound and 0 outbound movements were reviewed in full, together with the customer's trailing twelve-month history and 1 counterparty resolved to 1 hop.
Findings
No indicator of concealment, threshold avoidance or unexplained value was identified across the transaction, counterparty or screening evidence reviewed.
Mitigating evidence
(1) Transactions carry a consistent, verifiable economic purpose. 3 of 3 transactions reference an identifiable instrument — Catering contract Q3. [Payment reference fields] (2) Counterparties corroborated by documentation already on file. 1 counterparty is evidenced in the customer file: Contract on file since 2024. [Customer document store] (3) Activity consistent with declared expectation. Alerted volume 27,000 GBP sits within the declared monthly expectation of 30,000 GBP recorded for this relationship (independent coffee shop). [KYC profile CUS-118840] (4) Screening alert discounted on identified discriminators. Naylor (fuzzy, 0.71) discounted: DOB differs by 14 years; Listed entity resident in a different jurisdiction; No shared identifiers. [OFAC SDN + Consolidated, UN, EU, UK OFSI] (5) Established relationship with a stable alerting history. 7-year relationship with 1 alert in the trailing twelve months, all previously dispositioned without a filing. [Case management history]
Screening
OFAC SDN + Consolidated, UN, EU, UK OFSI: Naylor (fuzzy, 0.71) (score 0.71) — discounted. Name-only overlap on a common surname. Date of birth, nationality and all secondary identifiers diverge. Discounted under the institution's two-discriminator rule. Global PEP register: No match (score 0.11) — discounted. No PEP, RCA or close-associate match above the 0.85 review threshold.
Disposition
The activity is explained by the customer's documented profile and no further action is recommended. The alert is closed as a false positive. This determination was produced by heelius-investigator-4.2 · policy-pack us-bsa-2026.08 with a calibrated confidence of 97% and is subject to the institution's quality-assurance sampling programme.
Clean false positive. Contract on file resolves the round-value pattern.
R. Okafor · QA lead