Internal · Confidential · Sample

Intermediary Vetting Report

Name: Intermediary Vetting Report — Sample · DueVestor
Creator: DueVestor
License: https://duevestor.com/terms

Third-Party / Intermediary Vetting — FCPA-grade

Subject: Acme Holdings Ltd
Jurisdiction: British Virgin Islands
Report no.: DV-SAMPLE-D-0001
Generated: 2026-05-11

Recommendation

ESCALATE TO COMPLIANCE COMMITTEE

Escalation required

Enhanced Due Diligence required

Escalate to the Chief Compliance Officer before any onboarding decision. Do not proceed until reviewed.

Weighted Risk Score

54of 100

HIGH

Scale: LOW · MEDIUM · HIGH · SEVERE — derived from the weighted dimensions below.

Composite score 54 (HIGH). Recommendation: escalate to the compliance committee before any onboarding decision.

The lead drivers are Regulatory & Legal (two FCPA red flags + a high-risk jurisdiction), Adverse Media (a Pandora Papers reference), and the watchlist red flag. Together they cross the threshold into HIGH and trigger mandatory escalation.

Dimension	Weight	Score
Adverse Media	25%	60 / 100
Regulatory & Legal	20%	80 / 100
PEP Screening & Political	20%	20 / 100
Ownership Transparency	15%	40 / 100
Sanctions & Watchlist	10%	70 / 100
AML / Financial Crime	5%	70 / 100
ESG / Reputational	5%	50 / 100

How the score is derived

Each of the seven dimensions is scored 0–100 from the findings in its category and combined into a composite using the weights shown (Adverse Media 25%, Regulatory & Legal 20%, PEP Screening 20%, Ownership Transparency 15%, Sanctions & Watchlist 10%, AML / Financial Crime 5%, ESG / Reputational 5%). The most severe finding in each dimension sets the floor; additional corroborating findings add only a capped bump, so volume alone never overrides severity. A higher score reflects higher risk. The composite maps to one of four levels: LOW (0–24), MEDIUM (25–49), HIGH (50–74), SEVERE (75–100).

Materials and details considered

Legal name: Acme Holdings Ltd
Jurisdiction of incorporation: British Virgin Islands
Registration number: BVI-184422 (SYNTHETIC)
Headquarters: Tortola, BVI
Founded: 2014
Employees: 52

Main findings

ConfirmationCompanies House · DIFC · self-attestation
Two UBOs cross-verified across three independent sources
Both named UBOs confirmed via UK Companies House, DIFC registrar, and the subject's questionnaire. No discrepancies.^{[1, 2, 3]}
Red flagRegional watchlist · OpenSanctions
Potential watchlist match on a secondary director — single-source, unverified
A name screen returned a medium-confidence fuzzy match on one secondary director against a single regional watchlist, with no identifier-level cross-verification. The two primary UBOs screened clean. Per compliance policy, every match — including partial, single-source, or low-confidence — is flagged red and routed to a compliance officer for disposition; the system never auto-classifies it as a false positive.^[4]
ConcernFCPA red-flag taxonomy
High-risk jurisdiction + government-adjacent client base
BVI domicile + 60% of named clients are state-owned enterprises in tier-3 transparency jurisdictions. Two FCPA red flags trip simultaneously.^[5]
ConcernICIJ Offshore Leaks
Offshore data appearance — Pandora Papers (1 reference)
One named director appears in the Pandora Papers as the registered agent for an unrelated BVI shell. Not necessarily probative but requires escalation under DOJ guidance.^[6]

FCPA red-flag taxonomy

High-risk jurisdictionBVI — tier-3 transparency.

Government client base ≥ 25%60% of named clients are state-owned.

Unusual payment structureStandard wire payments.

Compensation above marketCommission rate 12% — top quartile but not extreme.

PEP / family of PEPNo PEP hits.

Sanctions or watchlist nexusClear screen.

Refusal to provide UBO dataUBOs disclosed and cross-verified.

Offshore data appearanceOne Pandora Papers reference.

Risk matrix

#	Criterion	Level	Rationale
1	UBO transparency	Low	UBOs cross-verified; no chain-of-ownership gaps.
2	Sanctions exposure	Medium–High	Primary UBOs clean; single-source potential match on a secondary director — a red flag pending compliance disposition.
3	Jurisdiction risk	High	BVI + tier-3 transparency client base.
4	Government interaction	Medium–High	60% state-owned client mix.
5	Offshore data appearance	Medium	One Pandora Papers reference on a director.
6	Litigation history	Low	No pending or historical international litigation.
7	Compliance posture	Medium	Anti-bribery policy in place but no annual training.
8	Overall recommendation	High	Two FCPA red flags + offshore reference → escalation required.

Country risk index

British Virgin Islands · CPI 53 (CPI rank: 60 / 180)

Lower CPI = higher corruption risk (Transparency International, 2024).

Source Coverage & Screening Transparency

Screened against DueVestor's full source network — 121 live sources across 37 jurisdictions. 4 sources returned findings; the remainder screened clean.

Source	Jurisdiction	Status
OpenSanctions	Global	Screened — findings returned
OFAC SDN	US	Screened — no matches
UN Consolidated	Global	Screened — no matches
Companies House	UK	Screened — findings returned
ICIJ Offshore Leaks	Global	Screened — findings returned
BVI FSC	BVI	Screened — findings returned
GDELT DOC 2.0	Global	Screened — no matches
CourtListener	US	Screened — no matches

Coverage is derived from what actually ran, never a fixed claim — an un-screened source is never shown as "clean".

Sources & Citations

Every finding in a live report links to a verifiable source; the numbers below match the markers in the body.

[1]
UK Companies House — first UBO verifiedCompanies House· 2026-05-06https://find-and-update.company-information.service.gov.uk/
[2]
DIFC Registrar — second UBO verifiedDIFC Registrar· 2026-05-05https://www.difc.ae/business/registrar-companies/
[3]
Self-attestation — ownership chain with no discrepanciesSubject questionnaire· 2026-05-01internal inference
[4]
OpenSanctions — medium-confidence fuzzy match, single source, on a secondary directorOpenSanctions· 2026-05-10https://www.opensanctions.org/
[5]
US DOJ guidance — two FCPA red flags trip simultaneouslyFCPA taxonomy· 2026-05-04https://www.justice.gov/criminal/criminal-fraud/foreign-corrupt-practices-act
[6]
ICIJ Offshore Leaks — one Pandora Papers reference on a directorICIJ Offshore Leaks· 2026-04-22https://offshoreleaks.icij.org/

Legal Disclaimer

Nature of the report

The Report is decision-support only. It is not a determination of guilt, wrongdoing, or identity, and a partial name match does not establish that the Subject is the listed party. It must not be the sole basis for any adverse action, and independent verification is required.

Accuracy & currency

The Report reflects information available from the Sources at the time of generation and may be incomplete or out of date. AI-generated content is labelled as such.

Warranties & limitation of liability

The Report is provided 'as is' without warranty of any kind. To the maximum extent permitted by law, DueVestor and its affiliates shall not be liable for any indirect, incidental, special, or consequential damages, and aggregate liability shall not exceed the fees paid for the Report.