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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.

Ownership document 2026-08-07 06:38 UTC

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.

Ownership document 2026-08-07 08:07 UTC

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.

SoW evidence 2026-08-08 10:13 UTC

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.

SoW evidence 2026-08-08 10:13 UTC

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.

SoW evidence 2026-08-08 10:14 UTC

Employer-submitted income records, 2015-2019: salary payments consistent with the client's claimed salary income and savings accumulation over the period.

Ownership document 2026-08-14 04:54 UTC

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

Ownership document 2026-08-17 03:29 UTC

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

Ownership document 2026-08-17 03:29 UTC

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.

Ownership document 2026-08-17 03:29 UTC

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.

RelationshipStatusRationaleRecorded
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

2026-08-07 06:02 UTC
Client onboarding started. MOEA company registry filing matched — confirms a 12% direct shareholding in ABC Trading Co Ltd.
2026-08-07 06:39 UTC
Offshore registry cross-search flagged 'W.C. Lin Family Trust' as a possible beneficiary structure tied to Wei-Chen L. (likely name variant 'W.C. Lin'); no trust deed available, so recorded as an inferred, unconfirmed beneficiary relationship pending primary documentation.
2026-08-07 08:00 UTC
Checked 'W.C. Lin Family Trust' against ICIJ's public Offshore Leaks Database (810,000+ entities from the Panama Papers, Paradise Papers, Pandora Papers, Bahamas Leaks, and Offshore Leaks investigations). No confirmed match -- ICIJ's own high-confidence match flag is false for every candidate returned. Closest candidates, for reference only, not treated as findings: 'W.M.D. Family Trust' (Entity node extracted from the Paradise Papers - Appleby data., similarity 80.0/100); 'LN FAMILY TRUST' (Entity node extracted from the Paradise Papers - Appleby data., similarity 75.0/100); 'MR FAMILY TRUST' (Entity node extracted from the Paradise Papers - Appleby data., similarity 65.0/100).
2026-08-07 08:07 UTC
BVI registry search and cross-referenced filing reveal a new intermediate entity, ABC Trading (BVI) Holdings Ltd, sitting between the W.C. Lin Family Trust (70% owner) and ABC Trading Co Ltd (20% owned by the BVI Holdings entity). This establishes a documented ownership chain, though the beneficiary link between Wei-Chen L. and the trust remains unconfirmed as before.
2026-08-14 04:54 UTC
Employer verification record confirms 'Lin Wei-Chen' is a name-variant (surname-first romanization) of existing client entity Wei-Chen L., corroborated by matching national ID and DOB. No new ownership details or percentages provided, so no edges added/updated."}
2026-08-17 03:29 UTC
Employer verification record confirms 'Lin Wei-Chen' (surname-first romanization) is the same individual as 'Wei-Chen L.' already on file, corroborated by matching national ID and DOB. No new ownership relationships or percentage changes disclosed in this document; existing 12% direct stake in ABC Trading Co Ltd remains as previously recorded.
2026-08-17 03:29 UTC
BVI registry search confirms the previously recorded 70% stake of W.C. Lin Family Trust in ABC Trading (BVI) Holdings Ltd and the 20% stake of ABC Trading (BVI) Holdings Ltd in ABC Trading Co Ltd, both already verified on file with matching percentages, so no edge updates are needed. Document explicitly notes the beneficiary chain back to the trust remains unconfirmed, consistent with the existing inferred Wei-Chen L. -> W.C. Lin Family Trust beneficiary edge.
2026-08-17 03:29 UTC
Offshore registry cross-search reaffirms the previously flagged, unconfirmed link between Wei-Chen L. and the W.C. Lin Family Trust but adds no new details (no trust deed produced, beneficiary status still unconfirmed). No new entities or edges to record since this restates an existing inferred relationship with less specificity.
2026-08-17 03:29 UTC
Checked 'Wei-Chen L.' against ICIJ's public Offshore Leaks Database (810,000+ entities from the Panama Papers, Paradise Papers, Pandora Papers, Bahamas Leaks, and Offshore Leaks investigations). No confirmed match -- ICIJ's own high-confidence match flag is false for every candidate returned. Closest candidates, for reference only, not treated as findings: 'Mr. Chen Wei' (Entity node extracted from the Offshore Leaks data., similarity 81.8/100); 'Chen Sau Wei' (Entity node extracted from the Offshore Leaks data., similarity 75.0/100); 'Chen Chen' (Entity node extracted from the Offshore Leaks data., similarity 60.0/100).
2026-08-17 03:29 UTC
Checked 'ABC Trading Co Ltd' against ICIJ's public Offshore Leaks Database (810,000+ entities from the Panama Papers, Paradise Papers, Pandora Papers, Bahamas Leaks, and Offshore Leaks investigations). No confirmed match -- ICIJ's own high-confidence match flag is false for every candidate returned. Closest candidates, for reference only, not treated as findings: 'ABC TRADING COMPANY LTD.' (Entity node extracted from the Bahamas Leaks data., similarity 78.3/100); 'HALCOM TRADING LTD.' (Entity node extracted from the Panama Papers data., similarity 72.2/100); 'LIN TRADING CO., LTD.' (Entity node extracted from the Panama Papers data., similarity 66.7/100).
2026-08-17 03:29 UTC
Checked 'W.C. Lin Family Trust' against ICIJ's public Offshore Leaks Database (810,000+ entities from the Panama Papers, Paradise Papers, Pandora Papers, Bahamas Leaks, and Offshore Leaks investigations). No confirmed match -- ICIJ's own high-confidence match flag is false for every candidate returned. Closest candidates, for reference only, not treated as findings: 'W.M.D. Family Trust' (Entity node extracted from the Paradise Papers - Appleby data., similarity 80.0/100); 'LN FAMILY TRUST' (Entity node extracted from the Paradise Papers - Appleby data., similarity 75.0/100); 'MR FAMILY TRUST' (Entity node extracted from the Paradise Papers - Appleby data., similarity 65.0/100).

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.”

WhenConfidenceStatusNote
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.”

WhenConfidenceStatusNote
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.”

WhenConfidenceStatusNote
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.