Approach
We only find whatanyone could find.
Every finding is sourced to a record a third party can reach without your cooperation: a register, a consolidated list, a court file, a published archive. No human sources. No discreet enquiries. The limit is the method, not a constraint on it.
The difference
Why this is not a risk report
Risk and investigations firms point these instruments at a counterparty, on behalf of somebody else. We point them at your own structure, with your cooperation, and the result is yours to read. Almost everything else follows from that reversal.
Subject
A counterparty, commissioned by someone on the other side of a decision.
Your own structure, commissioned by you or your counsel.
Sources
Public record, typically supplemented by human sources and discreet enquiries.
Only what a third party could reach without your cooperation. Nothing we could not have found about a stranger.
A finding
States that something exists and where it was found.
States what a third party sees, what it costs if it bites, and which adviser closes it.
Items with no remedy
Often left out, because they do not lead anywhere.
Recorded on the face of the register and marked closed.
Remediation
Frequently sold alongside the report by the same firm.
Handed to your counsel with a sequence. We do not act, and we do not bill for the fix.
Afterwards
A dated snapshot, ageing from the day it is delivered.
A structure map that is re-run whenever a fact changes.
Four more rules
Findings are priced and assigned, not described
A risk report tells you a subject appears in adverse media. A register line tells you what that will cost at the next periodic review, and which of your advisers closes it.
Findings are priced and assigned, not described.
A risk report tells you a subject appears in adverse media. A register line tells you what that will cost at the next periodic review, and which of your advisers closes it. Description is the cheap part. Consequence and ownership are the work, and they are what a lawyer can act on the same afternoon.
What cannot be fixed is recorded as closed.
Several findings in any review have no remedy: an article that will not be unwritten, a register entry that is permanent, a passport whose issuing programme has been withdrawn. We put those on the face of the register and say so. A document that lists only solvable problems is a sales document, and counsel reads it as one.
The order of the fixes is part of the finding.
Every remediation step leaves a dated public trace. Filed in the wrong sequence, a set of sensible corrections reads to a court or a tax authority as a response to scrutiny rather than good housekeeping. We set the order and the intervals, and counsel signs off each date. Two constraints are absolute: nothing is filed before the opinion that governs it, and no two acts are filed in the same month in different jurisdictions.
The map outlives the report.
A risk report is a snapshot that ages from delivery. The structure map is the durable asset: a new designation, a filing against an entity, a change in a country's listing or a fresh article is one re-run rather than a new engagement. It is also the reason monitoring costs a fraction of the first review.
The limits are deliberate
Each of these is a choice with a reason, not a gap in the service
No human sources and no approaches to third parties.
A finding obtained by speaking to someone is a finding the reviewing desk will not have. It inflates the report and degrades its predictive value.
No contact with banks, regulators, trustees or journalists.
The moment we speak for a client we are in the chain, and the client loses the ability to decide what is said and when.
No verification of source of wealth.
We record what a third party can establish and infer. Confirming the account itself is a different exercise, and it belongs to counsel and the institution.
No valuation, no asset tracing, no management of anything.
We hold nothing and advise on no asset.
No score.
The review measures the distance between what is believed private and what is not. A single number would conceal exactly the detail that makes the register usable.
No work without written instruction.
And none at all for designated persons, politically exposed persons, or subjects whose proximity to a designated party we judge unmanageable.
What the work produces
Why this matters to the output
A review built on privileged access would describe a world only we can see. Built on the open record, it describes the world your bank, your counterparty's lawyer and a journalist all see, which is the only version that predicts what any of them will do next.
Two components from one map.
A numbered register of findings with stress scenarios and a remediation sequence, and an interactive graph of the structure used to interrogate it. From there, a disclosure pack, pre-application dry runs, family briefs, an incident playbook and continuing re-screening.
The exclusions
What we are not
Not a law firm and not tax advisers.
Findings are delivered to instructing counsel; the legal and tax positions are theirs to opine on.
We do not manage, allocate, hold or advise on assets.
We are not an investment or wealth manager of any kind.
We do not verify a client's account of the source of his wealth.
We record what a third party can see and infer.
We do not value assets and we do not score the client.
The review measures the distance between what is believed to be private and what is not.
We do not speak to any bank, regulator, trustee or journalist on a client's behalf.
The moment we do, we are in the chain.
We do not help anyone around a control.
The work exists to make a file answerable, and where a finding cannot be fixed we say so and record it as closed.
The gate
Intake, and who we decline
The intake gate is part of the product. We decline designated persons and entities, politically exposed persons, and subjects whose proximity to a designated party we judge unmanageable. No work begins without written instruction from the client or his counsel, and we do not accept an instruction to prepare a report about a person who has not instructed it.
Engagements are documented, conflict-checked and confined to the structure named in the instruction.