E1 · Customer declaration
Example Trading Co declares Alex Example as its sole beneficial owner.
Evidence limit: Customer assertion. It does not independently establish ownership or control.
Illustrative review file
What should an EDD case file contain?
Follow a corporate review from source evidence to a human decision. Inspect the ownership calculation, the gaps that remain and the criteria you could use to evaluate a pilot.
Case EXAMPLE-001
A periodic review reveals an ownership discrepancy
Example Trading Co is due for review. Its new declaration conflicts with the supplied ownership records. The reviewer asks for an enhanced review of ownership and the unresolved screening result.
- Queue
- Corporate periodic review / EDD
- Scope
- Ownership reconciliation and screening exception
- File status
- Prepared with unresolved gaps
- Decision status
- Pending customer reviewer
1. Keep each finding attached to its evidence
A real file should preserve the exact source, retrieval time, document version and permitted access route. These four entries are fictional teaching inputs.
E2 · Company register extract
Example Holdings Co owns 60% of Example Trading Co; Casey Example owns the remaining 40%.
Evidence limit: Fictional extract dated 10 October 2026. A real review must establish source authenticity and currency.
E3 · Parent shareholder register
Alex Example owns 70% of Example Holdings Co; Morgan Example owns 30%.
Evidence limit: Fictional share register. Voting rights, control agreements and other arrangements have not been supplied.
E4 · Illustrative screening result
A name-only result resembles Alex Example. The result has no date of birth or other unique identifier.
Evidence limit: An intentionally unresolved synthetic match. Neither a confirmed match nor a basis for automatic dismissal.
2. Show the calculation and its limits
Economic interests implied by E2 and E3 are reproducible. Beneficial ownership and control still require the applicable policy, legal criteria and sufficient supporting evidence.
| Person | Calculation | Interest | Evidence |
|---|---|---|---|
| Alex Example | 60% × 70% | 42% indirect | E2 + E3 |
| Morgan Example | 60% × 30% | 18% indirect | E2 + E3 |
| Casey Example | 40% direct | 40% direct | E2 |
The interests total 100%. E1's sole-owner declaration is inconsistent with E2 and E3. No conclusion about legal beneficial-owner status follows from these percentages alone: voting arrangements, control by other means and the institution's applicable requirements remain to be assessed.
3. Make the unresolved work explicit
Ownership discrepancy
Request a corrected ownership declaration and the missing control information. Record whether the difference is explained by a subsequent change, a document error or another evidenced reason. Preserve the conflicting versions.
Owner: designated customer reviewer / evidence-request owner.
Unresolved name match
E4 supplies too little information to confirm or clear the match. Seek permitted identifying evidence and route the exception to the designated reviewer under the customer's policy. Do not infer that Alex Example is the listed person.
Status: unresolved; no automatic clearance.
Example handoff memo
E2 and E3 imply economic interests of 42%, 18% and 40%, which conflict with the sole-owner declaration in E1. Control arrangements remain undocumented. The E4 name-only result cannot be resolved with the supplied identifiers. The file is ready for review of these findings, but the evidence is insufficient to close the ownership and screening questions. Request the missing information and escalate under the customer's policy. No risk rating, relationship decision or filing decision is made in this example.
Reviewer record: pending · policy version: to be supplied · decision: pending · reasoning and sign-off time: to be completed by the authorised reviewer.
4. Agree how the pilot will be evaluated
Set thresholds with your compliance and operations owners before the pilot. Use a representative mix of cases and an expert-reviewed reference set. This example sets no universal pass rate and reports no observed results.
Evidence completeness
Cases containing every policy-required evidence item divided by reviewed cases.
Record incomplete files and escalated gaps separately; an escalation does not make a file complete.
Ownership traceability
Cases with reproducible ownership calculations and identified control gaps divided by cases needing ownership analysis.
Verify the arithmetic and the underlying evidence separately.
First-pass acceptance
Files accepted without correction divided by files submitted to your reviewer.
Record rejection reasons and case complexity. Acceptance is not customer approval.
Escalation quality
Missed-trigger rate: cases not escalated despite an expert-confirmed trigger divided by all reference cases requiring escalation. Unnecessary-escalation rate: cases escalated without an expert-confirmed trigger divided by all reference cases not requiring escalation.
Report the two rates separately. If either denominator is zero, report its counts without a rate. Record false clearances separately from other missed triggers.
Retained reviewer time
Total reviewer minutes divided by cases reviewed, with median and range alongside it.
Include correction and re-review time.
Cost per accepted file
Provider, data, setup allocation, internal review and rework costs divided by accepted files.
State the period, currency and exclusions. If none are accepted, report the cost and count without a rate.
For each metric, record the case population, numerator, denominator, period, reference outcome, acceptance owner and agreed threshold. Compare equivalent workloads. Report unresolved cases and errors explicitly; an accepted review file is not the same as an approved customer relationship.
Use this example to scope your own queue
Bring a representative case type, the evidence your team can provide and your acceptance criteria. Confirm what the service can deliver before agreeing a pilot.