Service · method · deliverables
The ExposureReview
One structure, mapped in full. Sixteen tests run across it. Every finding returned as a numbered line that states what a third party can see today, what it costs if it bites, and who fixes it.
The method
Sixteen tests in four families
Visibility
What others can already establish without the client's cooperation.
Screening
What commercial tools and the public lists return on each name, false positives included
Proximity
Hops from any node to a designated, politically exposed or grey-listed party, through any relationship
Transparency
What sits on a public or authority-accessible register today, against what is believed private
History
Former directorships, disposed and dissolved entities, which desks retain indefinitely and clients rarely recall
Structure
Whether the paper holds when it is tested.
Substance
The shell heuristics banks apply and the substance tests authorities apply
Control
Whether assets given away remain, on the documents, controlled by the giver
Provider
Trustees, nominees and corporate-services firms as single points of failure outside the client's control
Claims
Who can reach the assets, and through which instrument.
Matrimonial
What a spouse can reach under the governing regime, and what she is exposed to in return
Encumbrance
Guarantees, pledges and change-of-control clauses, registered or not. The unregistered ones do the damage
Litigation
Judgments, awards and claims, and where each is enforceable
Succession
What stops if the principal cannot act for six weeks
Resilience
What breaks, and in what order, when one fact changes.
Concentration
Single bank, single trustee, single signatory, single jurisdiction: what fails together
Residence
Personal tax residence tested against each jurisdiction's own rule rather than the certificate held
Status
Durability of the citizenships and residence permits the structure quietly assumes
Physical
What the public registers disclose about where the family actually lives
Trail
The visibility each remediation step itself creates, and the order in which the sequence reads worst
What you receive
Two components, from one underlying map.
The register is the document counsel works from; the graph is the instrument used to interrogate it.
Component one
Exposure Register
A numbered register of findings, ordered by severity and by how early a desk or an authority meets each item.
Every line carries the same fields
Node
The person, entity, asset, account or claim it attaches to
Module
Which of the sixteen tests produced it
Severity
Calibrated to institutional behaviour, not to statute
Seen
What a third party can establish today, in their language
Cost
The realised consequence, not the theoretical one
Owner
Who acts: counsel, trustee, provider or principal
Status
Open, in progress, or closed
The register also carries stress scenarios one fact changed, every test re-run, the cascade shown in order and a remediation sequence ordered by dependency rather than severity, because several fixes cannot safely be filed before others.
Component two
Exposure Graph
The same structure drawn as a map: people, entities, assets, accounts, counterparties, historic holdings and contingent claims, with every ownership, control, family, funding and security relationship between them.
How the map is read
Ring
Each node coloured by its worst finding
Edges
Ownership, control, beneficiary, funding, security, former holding — each dated
Filter
Isolate any one of the sixteen tests across the whole structure
Scenario
Replay a shock and watch the cascade order resolve on the map
Node file
What a third party sees, every connection, every finding
The map is the durable asset. Once drawn, each new list update, filing, article or life event is one re-run rather than a new engagement.
Severity
How findings are rated
Severity is calibrated to how institutions, authorities and courts have actually behaved, not to the text of any statute. A finding keeps its rating until the register is reissued.
Critical
A desk declines or freezes on this alone, or an authority can reach back years. Nothing else moves until it is addressed.
High
Routes every application to enhanced due diligence, or produces a legal loss when tested.
Medium
Dormant until a named trigger, then costly. Appears in the stress scenarios.
Low
Visible to a third party today at no present cost. Recorded so that it stops being mistaken for private.
Findings that cannot be fixed are marked closed and stay in the register. A review that lists only solvable problems is a sales document, and counsel reads it as one.
Deliverables
The register diagnoses. The deliverables that follow are what change an outcome, and all of them run off the same map.
Deliverable
What it contains
Issued
Exposure Register
The mapped structure, the numbered findings, the stress scenarios, the remediation sequence and the constraint governing the order of filings.
IssuedPhase 1
Disclosure pack
The mirror of the register: what an institution will ask for, assembled before it asks. Identity set and certified translations; a source-of-wealth narrative with its supporting documents; the evidence needed to discount a false screening match; a registry extract and a short explanation for each historic entity; the full guarantee, pledge and judgment schedule; a signed structure chart; counsel letters.
IssuedPhase 2
Pre-application dry run
One named institution's published and observed onboarding policy run against the map, returning a go, fix-first or do-not-apply verdict with the specific reason, the documents that institution will require, and the findings that must close before filing.
IssuedPer application
Monitoring
Periodic re-screening of every node against the list, register, court-record and media sources, with alerts on a new designation within two hops, a filing against any entity, a strike-off warning, a regulatory action against a provider, a country-list change touching a node, and new adverse media. Each alert arrives as a register line, not a notification.
IssuedContinuing
Family brief
One page for each connected person: what they carry by virtue of the connection, what they will be asked at their own bank, what is already public about them, and what to do when asked. Written to be read by a non-specialist and shown to their own advisers.
IssuedPhase 2
Incident playbook
The first seventy-two hours after each scenario in the register: who is called and in what order, which documents go where, what is said to the institution, what is said to nobody, and which decisions cannot be taken without counsel. Written before the event, because the sequence is what gets lost in the first hour.
IssuedPhase 2
What we search
Every finding cites at least one source a third party could reach without the client's cooperation. Client documents are used to confirm what the public record already implies, and to establish the contingent items no register holds.
- Consolidated sanctions and politically-exposed-person datasets
- The US, EU and UK consolidated lists, by name and alias
- Company registers and officer histories, current and former
- Beneficial-ownership registers, where accessible
- Property and overseas-entity registers
- Trust registration records
- Judgment, insolvency and court-record databases
- Free-zone and offshore company registers
- Published leak databases
- Adverse media, in the relevant languages
- Registered security, pledge and charge filings
- Commercial screening tools, run under the instructing firm's licence
- Client-supplied deeds, mandates, facility agreements and presence records
Engagement
Work is taken on written instruction, normally from counsel, so that privilege attaches to the output and the relationship with the client stays where it belongs.
Instruction and conflicts
Scope agreed in writing, conflicts checked, intake gate applied. No work begins before this is complete.
Mapping
Sessions with the principal and counsel to draw the structure, including an adversarial pass on former holdings and signatures given, which is where the items nobody volunteers are found.
The sixteen modules
Run across every node, against public, commercial and client-supplied sources.
Register and graph
Delivered to instructing counsel with the stress scenarios and the remediation sequence.
Phase two, if instructed
Disclosure pack, family brief and incident playbook, built on the findings.
Monitoring, if signed
The map is re-screened on a periodic cycle and the register is reissued with a new version whenever a finding changes.
Fees are quoted per engagement and in advance of it. Scope follows the number of persons and entities in the structure, the number of jurisdictions and registers involved, the depth of the historic sweep, and whether phase two and monitoring are instructed. Dry runs are priced per application.
Scope and limits
The map covers current holdings, the historic layer, and contingent claims such as guarantees, pledges and unsatisfied judgments. The historic and contingent tiers are the parts no client supplies unprompted and the parts every desk retains.
Legal and tax questions
We do not give legal or tax advice. Where a finding turns on a question of law, a residence test, the effect of a deed, the reach of a regime, it is flagged for counsel and not answered.
Source of wealth
We do not verify the client's account of his source of wealth, and the register says so on its face.
Valuation and management
We do not value assets, advise on investments, or hold or manage anything.
Third-party contact
We do not contact any bank, regulator, trustee, counterparty or journalist on a client's behalf.
Subjects we decline
We decline designated persons and entities, politically exposed persons, and subjects whose proximity to a designated party we judge unmanageable.
How the work is held.
The map, the register and every document gathered are kept in an encrypted store under a key the client controls. Output goes to instructing counsel. Nothing is retained once an engagement closes unless a monitoring mandate is signed, and then only the map and the register, for as long as that mandate runs.
Specimen
A complete specimen review, a fictional engagement built to show the form of both components is available to professional advisers on request. It is not published.