AI decision audit trail
Wei-Chen L. — ABC Trading Co Ltd
Mapped to Taiwan FSC's "Guidelines for the Use of AI in the Financial Industry" (June 20, 2024), four-stage AI lifecycle: planning & design; data collection; model building & validation; deployment & monitoring. Generated 2026-10-01 22:03 UTC from case data current as of that time.
Not a compliance determination
FSC guidance requires firms using third-party generative AI to designate personnel who "objectively and professionally manage" the risk and to keep records of AI model design and decision-making to assess fairness. This document is that record for this case — it is evidence to support a human reviewer's decision, not a substitute for one.
Stage 1
Overview
This case draws on AI assistance in two places: identifying the beneficial owners of the subject entity and how they're connected, and assessing the evidence behind the client's source-of-wealth claims. In both cases, the AI does not make the final call — it produces a confidence assessment and a written explanation, and a human reviewer decides what happens next. Every AI response is captured in a fixed, consistent format specifically so it can be logged and reviewed here, rather than left as free-form text. AI model used: Claude, developed by Anthropic.
Stage 2
Data collection
Every document submitted for this case is kept exactly as received and is the only basis for any AI-derived finding that follows from it. 9 document(s) submitted to date.
Offshore registry cross-search initiated (not client-provided): 'W.C. Lin Family Trust' identified as a possible beneficiary structure connected to Wei-Chen L. Trust deed has not been produced; beneficiary status is not yet confirmed by primary documentation.
BVI corporate registry search: 'W.C. Lin Family Trust' holds a 70% interest in 'ABC Trading (BVI) Holdings Ltd'. A cross-referenced BVI corporate filing shows 'ABC Trading (BVI) Holdings Ltd' holds a 20% interest in ABC Trading Co Ltd. The beneficiary chain back to the trust has not been independently confirmed.
Property registry search, Taipei property: title has been held under a different registered owner since 2016. This is inconsistent with the client's claimed rental income from this property; the client-submitted lease copy does not reconcile with registry records.
TWSE-style ownership-change filing, 2019: share transfer recorded for ABC Trading Co Ltd, consistent with the claimed 2019 share sale — filing date and share count match the client's narrative.
Employer-submitted income records, 2015-2019: salary payments consistent with the client's claimed salary income and savings accumulation over the period.
Employer verification record: shareholder listed as 'Lin Wei-Chen' (surname-first romanization). National ID A123456789, date of birth 1978-05-12, matches the 'Wei-Chen L.' onboarding record already on file for ABC Trading Co Ltd.
Identifiers were withheld before this was sent to the AI
Employer verification record: shareholder listed as 'Lin Wei-Chen' (surname-first romanization). National ID [NATIONAL-ID-REDACTED], date of birth [DATE-OF-BIRTH-REDACTED], matches the 'Wei-Chen L.' onboarding record already on file for ABC Trading Co Ltd.
date of birth: matched Wei-Chen L. on file
national id: matched Wei-Chen L. on file
Employer verification record: shareholder listed as 'Lin Wei-Chen' (surname-first romanization). National ID A123456789, date of birth 1978-05-12, matches the 'Wei-Chen L.' onboarding record already on file for ABC Trading Co Ltd.
Identifiers were withheld before this was sent to the AI
Employer verification record: shareholder listed as 'Lin Wei-Chen' (surname-first romanization). National ID [NATIONAL-ID-REDACTED], date of birth [DATE-OF-BIRTH-REDACTED], matches the 'Wei-Chen L.' onboarding record already on file for ABC Trading Co Ltd.
date of birth: matched Wei-Chen L. on file
national id: matched Wei-Chen L. on file
BVI corporate registry search: 'W.C. Lin Family Trust' holds a 70% interest in 'ABC Trading (BVI) Holdings Ltd'. A cross-referenced BVI corporate filing shows 'ABC Trading (BVI) Holdings Ltd' holds a 20% interest in ABC Trading Co Ltd. The beneficiary chain back to the trust has not been independently confirmed.
Offshore registry cross-search initiated (not client-provided): 'W.C. Lin Family Trust' identified as a possible beneficiary structure connected to Wei-Chen L. Trust deed has not been produced; beneficiary status is not yet confirmed by primary documentation.
Stage 3
Model building & validation
This system does not train or customize its own AI model — it uses a general-purpose model provided by a third party (Anthropic). Taiwan's FSC guidance is explicit that firms in this position must still actively manage that risk rather than accept the AI's output uncritically. To do that, every AI output passes through the checks below before anything is added to the case record:
A new name is only linked to an existing person or company when the AI positively confirms it's the same one.
Otherwise it's treated as new and kept separate. This is what lets 'Lin Wei-Chen' — a different ordering of the same name — correctly match the existing 'Wei-Chen L.' record instead of being logged as a different person.
A known ownership percentage can never be silently erased by a later, less specific document.
If a new document doesn't state a specific percentage for a relationship that's already on file, the existing figure is kept rather than cleared. This protects a confirmed stake from being lost just because a later document mentioned the relationship without repeating the number.
Indirect ownership through a chain of companies is calculated independently, not estimated by the AI.
The AI is only asked to report direct relationships a document actually states — for example, 'Company A owns 70% of Company B.' Any indirect stake reachable through a chain of companies is then calculated separately by the system itself, so the same ownership can't be counted twice.
Every confidence score comes with a written reason, and the system leans cautious.
The AI is never allowed to return a bare number — each score must include a short explanation. It's also instructed to weigh the two directions differently: evidence that contradicts a claim should lower confidence sharply, while evidence that supports it should raise confidence more gradually. Missing a real problem is treated as more costly than being overly cautious.
National ID numbers and dates of birth are never sent to the AI model.
When a submitted document contains one, it's compared locally, within our own systems, against the record already on file — the AI is only ever told whether that comparison matched, not the number itself. This keeps the raw identifier from ever reaching the third-party AI provider, while still letting the system use a positive match as supporting evidence when resolving a name variant.
Stage 4
Deployment & monitoring
Beneficial ownership — current state
Company Act — 10% threshold
12.0% confirmed
AML Act — 25% threshold
26.0% potential
Escalated for human review
Potential aggregate control (26.0%) crosses the 25% UBO threshold pending confirmation of inferred relationships. No automated action closes this case.
| Relationship | Status | Rationale | Recorded |
|---|---|---|---|
| Wei-Chen L. → ABC Trading Co Ltd (12% direct) | verified | MOEA company registry filing, 2024. | 2026-08-07 06:02 |
| Wei-Chen L. → W.C. Lin Family Trust (beneficiary (unconfirmed)) | inferred | Offshore registry cross-search identified a possible trust structure connected to Wei-Chen L., but no trust deed has been produced to confirm beneficiary status. | 2026-08-07 06:39 |
| W.C. Lin Family Trust → ABC Trading (BVI) Holdings Ltd (70% direct) | verified | BVI corporate registry search directly shows W.C. Lin Family Trust holding a 70% interest in ABC Trading (BVI) Holdings Ltd. | 2026-08-07 08:07 |
| ABC Trading (BVI) Holdings Ltd → ABC Trading Co Ltd (20% direct) | verified | Cross-referenced BVI corporate filing shows ABC Trading (BVI) Holdings Ltd holds a 20% interest in ABC Trading Co Ltd. | 2026-08-07 08:07 |
How the ownership structure was uncovered
Source-of-wealth claims — how confidence changed over time
Share sale, ABC Trading Co Ltd — 2019
NT$28,000,000 claimed — “Sold my shares in ABC Trading Co in 2019.”
| When | Confidence | Status | Note |
|---|---|---|---|
| 2026-08-07 06:02 | 50% | pending | Client narrative only — no independent evidence yet. |
| 2026-08-08 10:14 | 85% | corroborated | TWSE-style ownership-change filing independently confirms a 2019 share transfer in ABC Trading Co Ltd, with filing date and share count matching the client's narrative. This is a third-party regulatory record, not client-submitted paperwork, so it substantially raises confidence in the claimed share sale. |
Salary income, 2015–2019
NT$6,500,000 claimed — “Salary income, accumulated as savings, 2015 onward.”
| When | Confidence | Status | Note |
|---|---|---|---|
| 2026-08-07 06:02 | 40% | pending | Client narrative only — no independent evidence yet. |
| 2026-08-08 10:14 | 72% | corroborated | Employer-submitted income records for 2015-2019 independently confirm salary payments consistent with the client's claimed amounts, supporting the accumulation-as-savings narrative. Confidence raised significantly since this is third-party (employer) documentation rather than client-submitted paperwork, though full corroboration of the exact savings accumulation figure would require bank statements. |
Rental income, Taipei property
NT$4,000,000 claimed — “Rental income from a Taipei property.”
| When | Confidence | Status | Note |
|---|---|---|---|
| 2026-08-07 06:02 | 55% | pending | Client-submitted lease copy only. |
| 2026-08-08 10:13 | 10% | downgraded | Official property registry search shows title has been held by a different registered owner since 2016, directly conflicting with the client's claim of rental income from this Taipei property. Client-submitted lease copy does not reconcile with independent registry records, indicating the claim is likely unsubstantiated or misrepresented. |
Aggregate check — claimed sources vs actual assets
Claimed sources total NT$38,500,000 against total assets of NT$45,000,000. A gap of NT$6,500,000 has no claimed source, independent of any single claim's status.