AI decision audit trail
Chen Li-Wen — Golden Harvest Foods 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 21:59 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. 20 document(s) submitted to date.
1. `MOEA/GCIS company registration extract, 2024 — Business_Accounting_NO: 70556219, Company_Name: Golden Harvest Foods Co Ltd, Company_Status: 01 (核准設立 — Approved/Registered). Shareholder register (bank-obtained, not part of the GCIS extract itself) lists Chen Li-Wen holding a 5% direct equity stake.` 2. `Private banking onboarding file: identity verification confirms National ID A234567890, date of birth 22 March 1975, for client 'Li-Wen Chen' — matches the record on file for Chen Li-Wen.` 3. `Hong Kong Companies Registry annual return, 2024: Li-Wen Chen holds a 60% equity stake in Pacific Rim Holdings Ltd.` 4. `Hong Kong Companies Registry annual return, 2024: Pacific Rim Holdings Ltd holds a 30% equity stake in Golden Harvest Foods Co Ltd.` 5. `Corporate intelligence search result: Pacific Rim Holdings Ltd is reported to have a beneficial link to Silverline Capital Ltd, a BVI-registered entity — this connection has not been confirmed through primary documentation.` 6. `BVI Registry extract, 2024: Silverline Capital Ltd holds a 15% equity stake in Golden Harvest Foods Co Ltd.`
Identifiers were withheld before this was sent to the AI
1. `MOEA/GCIS company registration extract, 2024 — Business_Accounting_NO: 70556219, Company_Name: Golden Harvest Foods Co Ltd, Company_Status: 01 (核准設立 — Approved/Registered). Shareholder register (bank-obtained, not part of the GCIS extract itself) lists Chen Li-Wen holding a 5% direct equity stake.` 2. `Private banking onboarding file: identity verification confirms National ID [NATIONAL-ID-REDACTED], date of birth [DATE-OF-BIRTH-REDACTED], for client 'Li-Wen Chen' — matches the record on file for Chen Li-Wen.` 3. `Hong Kong Companies Registry annual return, 2024: Li-Wen Chen holds a 60% equity stake in Pacific Rim Holdings Ltd.` 4. `Hong Kong Companies Registry annual return, 2024: Pacific Rim Holdings Ltd holds a 30% equity stake in Golden Harvest Foods Co Ltd.` 5. `Corporate intelligence search result: Pacific Rim Holdings Ltd is reported to have a beneficial link to Silverline Capital Ltd, a BVI-registered entity — this connection has not been confirmed through primary documentation.` 6. `BVI Registry extract, 2024: Silverline Capital Ltd holds a 15% equity stake in Golden Harvest Foods Co Ltd.`
date of birth: matched Chen Li-Wen on file
national id: matched Chen Li-Wen on file
1. `Company annual reports and dividend payment records confirm dividend distributions to Chen Li-Wen consistent with the claimed amounts and period, 2016-2022.` 2. `Land registry transfer record confirms the sale of a commercial property in Taichung in 2020, with a declared sale price of NT$11,000,000 — significantly below the NT$18,000,000 claimed.`
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 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: no match found on file
national id: no match found 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: no match found on file
national id: no match found 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: no match found on file
national id: no match found on file
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 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: no match found on file
national id: no match found 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: no match found on file
national id: no match found on file
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 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: no match found on file
national id: no match found on file
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.
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: no match found on file
national id: no match found 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: no match found on file
national id: no match found 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: no match found on file
national id: no match found 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: no match found on file
national id: no match found 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: no match found on file
national id: no match found on file
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.
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
23.0% confirmed
AML Act — 25% threshold
32.0% potential
Escalated for human review
Potential aggregate control (32.0%) crosses the 25% UBO threshold pending confirmation of inferred relationships. No automated action closes this case.
| Relationship | Status | Rationale | Recorded |
|---|---|---|---|
| Chen Li-Wen → Golden Harvest Foods Co Ltd (5% direct) | verified | Bank-obtained shareholder register lists Chen Li-Wen holding a 5% direct equity stake in Golden Harvest Foods Co Ltd. | 2026-08-17 08:31 |
| Chen Li-Wen → Pacific Rim Holdings Ltd (60% direct) | verified | HK Companies Registry annual return 2024 states Li-Wen Chen holds 60% equity stake in Pacific Rim Holdings Ltd. | 2026-08-17 08:31 |
| Pacific Rim Holdings Ltd → Golden Harvest Foods Co Ltd (30% direct) | verified | HK Companies Registry annual return 2024 states Pacific Rim Holdings Ltd holds 30% equity stake in Golden Harvest Foods Co Ltd. | 2026-08-17 08:31 |
| Pacific Rim Holdings Ltd → Silverline Capital Ltd (beneficial link (unconfirmed)) | inferred | Corporate intelligence search reports an unconfirmed beneficial link between Pacific Rim Holdings Ltd and Silverline Capital Ltd, not verified by primary documentation. | 2026-08-17 08:31 |
| Silverline Capital Ltd → Golden Harvest Foods Co Ltd (15% direct) | verified | BVI Registry extract 2024 states Silverline Capital Ltd holds a 15% equity stake in Golden Harvest Foods Co Ltd. | 2026-08-17 08:31 |
| Lin Wei-Chen → W.C. Lin Family Trust (possible trust beneficiary (unconfirmed)) | inferred | Offshore registry cross-search suggests Lin Wei-Chen may be a beneficiary of the W.C. Lin Family Trust, but no trust deed has been produced and beneficiary status is unconfirmed by primary documentation. | 2026-08-20 22:56 |
| W.C. Lin Family Trust → ABC Trading (BVI) Holdings Ltd (70% direct) | verified | BVI corporate registry search shows W.C. Lin Family Trust holds a 70% interest in ABC Trading (BVI) Holdings Ltd. | 2026-08-20 22:56 |
| 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. | 2026-08-20 22:56 |
How the ownership structure was uncovered
Source-of-wealth claims — how confidence changed over time
Dividend income from family manufacturing business, 2016–2022
NT$28,000,000 claimed
| When | Confidence | Status | Note |
|---|---|---|---|
| 2026-08-17 08:30 | 0% | pending | No evidence submitted yet. |
| 2026-08-17 08:34 | 85% | corroborated | Company annual reports and dividend payment records are third-party/official filings that confirm dividend distributions to Chen Li-Wen consistent with claimed amounts and period 2016-2022, providing independent corroboration. |
| 2026-08-20 01:55 | 82% | corroborated | This filing documents a 2019 share transfer for ABC Trading Co Ltd, not dividend income specifically; it may indirectly support the client's ownership stake underlying dividend claims but does not independently verify the 2016-2022 dividend payments themselves. Confidence left essentially unchanged as this document does not add direct evidence for the dividend income claim. |
| 2026-08-20 06:52 | 82% | corroborated | This filing pertains to a 2019 share transfer of ABC Trading Co Ltd, not to dividend income from the family manufacturing business; it does not independently add or detract from this claim. |
| 2026-08-20 09:12 | 82% | corroborated | This filing pertains to a 2019 share transfer at ABC Trading Co Ltd, which is not directly related to the dividend income claim for 2016-2022; no new evidence provided for this claim. |
Sale of Taichung commercial property, 2020
NT$18,000,000 claimed
| When | Confidence | Status | Note |
|---|---|---|---|
| 2026-08-17 08:30 | 0% | pending | No evidence submitted yet. |
| 2026-08-17 08:34 | 30% | downgraded | Land registry record independently confirms the sale occurred in 2020, but the declared sale price of NT$11,000,000 is significantly below the NT$18,000,000 claimed, indicating a material discrepancy that undermines the claimed source-of-wealth amount. |
| 2026-08-20 01:54 | 8% | downgraded | Document concerns a Taipei property with title held by a different registered owner since 2016 and a lease that doesn't reconcile with registry records; this is unrelated to the Taichung commercial property sale claim but reflects a broader pattern of documentation inconsistency, further undermining confidence in unverified property-related claims from this client. |
| 2026-08-20 01:55 | 8% | downgraded | Document concerns a share transfer in ABC Trading Co Ltd, unrelated to the claimed sale of a Taichung commercial property; no independent evidence found for the real estate transaction, so confidence remains low and status unchanged. |
| 2026-08-20 06:52 | 8% | downgraded | Document concerns a 2019 share transfer in ABC Trading Co Ltd, unrelated to the claimed 2020 sale of a Taichung commercial property; it provides no corroboration for this specific claim and the property sale claim remains unsupported. |
| 2026-08-20 09:12 | 8% | downgraded | The filing concerns a share transfer, not a property sale, and does not corroborate the claimed 2020 Taichung commercial property sale. |
| 2026-09-08 07:01 | 3% | downgraded | Document pertains to a Taipei property, not the Taichung commercial property in question, so it provides no direct evidence either way for this claim; existing low confidence for claim 29 is maintained/further reduced out of caution given a pattern of unreliable client-submitted property documentation. |
Aggregate check — claimed sources vs actual assets
Claimed sources total NT$46,000,000 against total assets of NT$60,000,000. A gap of NT$14,000,000 has no claimed source, independent of any single claim's status.