AI decision audit trail

Priya Sharma — Meridian Textiles Pte 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.

SoW evidence 2026-08-20 05:49 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.

Ownership document 2026-08-20 05:50 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: no match found on file

national id: no match found on file

Ownership document 2026-08-20 06:42 UTC

Identifiers were withheld before this was sent to the AI

date of birth: no match found on file

national id: no match found on file

Ownership document 2026-08-20 06:43 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.

SoW evidence 2026-08-20 06:43 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 2026-08-20 06:43 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 2026-08-20 06:51 UTC

Identifiers were withheld before this was sent to the AI

date of birth: no match found on file

national id: no match found on file

SoW evidence 2026-08-20 06:51 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.

Ownership document 2026-09-22 22:51 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.

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

0% confirmed

AML Act — 25% threshold

0% potential

Relationship	Status	Rationale	Recorded
Lin Wei-Chen → W.C. Lin Family Trust (possible 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 to confirm this.	2026-08-20 06:43
W.C. Lin Family Trust → ABC Trading (BVI) Holdings Ltd (70% direct (BVI registry))	verified	BVI corporate registry search shows W.C. Lin Family Trust holds a 70% interest in ABC Trading (BVI) Holdings Ltd.	2026-09-22 22:51
ABC Trading (BVI) Holdings Ltd → ABC Trading Co Ltd (20% direct (BVI filing))	verified	Cross-referenced BVI corporate filing shows ABC Trading (BVI) Holdings Ltd holds a 20% interest in ABC Trading Co Ltd.	2026-09-22 22:51

How the ownership structure was uncovered

2026-08-20 05:50 UTC

Employer verification record introduces 'Lin Wei-Chen' as a shareholder, purportedly matching a 'Wei-Chen L.' onboarding record for ABC Trading Co Ltd - however, neither ABC Trading Co Ltd nor this individual (Wei-Chen L.) exist in our current case entity list, and the ID/DOB check returned no match against entities on file, so this cannot be linked to the known case entities (Priya Sharma, Meridian Textiles Pte Ltd). No verifiable ownership edge recorded; flagged for manual follow-up to determine relevance to this case.

2026-08-20 06:42 UTC

Employer verification record reaffirms Lin Wei-Chen as a shareholder tied to ABC Trading Co Ltd, matching the existing entity by name; however, the ID/DOB comparison against records on file did not corroborate this match. No new or changed ownership percentage or relationship detail is provided, so no edge is recorded."

2026-08-20 06:43 UTC

Offshore registry cross-search flagged a possible link between Lin Wei-Chen and an entity called 'W.C. Lin Family Trust', suggesting Lin Wei-Chen may be a beneficiary. This remains unconfirmed as no trust deed has been produced; recorded as an inferred beneficiary relationship pending further documentation."

2026-08-20 06:51 UTC

Employer verification record confirms 'Lin Wei-Chen' (surname-first romanization) is the same individual as existing entity 'Wei-Chen L.' / Lin Wei-Chen, a shareholder associated with ABC Trading Co Ltd. No new ownership/beneficiary relationships or percentages are disclosed in this document; the existing shareholder link and trust beneficiary status remain as previously recorded."

2026-09-22 22:51 UTC

BVI registry search and cross-referenced filing establish a two-hop corporate chain: W.C. Lin Family Trust holds 70% of new entity ABC Trading (BVI) Holdings Ltd, which in turn holds 20% of ABC Trading Co Ltd. The trust's ultimate beneficiary (previously flagged as possibly Lin Wei-Chen) remains unconfirmed, so that existing inferred edge is left unchanged.

2026-09-22 22:52 UTC

Checked 'Priya Sharma' 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: 'Gaurav SHARMA' (Entity node extracted from the Offshore Leaks data., similarity 61.5/100); 'SHARMA LTD' (Entity node extracted from the Pandora Papers - SFM Corporate Services data., similarity 58.3/100); 'Sharma Limited' (Entity node extracted from the Panama Papers data., similarity 57.1/100).

Source-of-wealth claims — how confidence changed over time

Sale of prior business stake, 2018

S$12,000,000 claimed

When	Confidence	Status	Note
2026-08-19 11:19	0%	pending	No evidence submitted yet.
2026-08-20 05:49	72%	corroborated	TWSE-style ownership-change filing independently confirms a 2019 share transfer for ABC Trading Co Ltd, with filing date and share count matching the client's narrative of a prior business stake sale.
2026-08-20 06:43	88%	corroborated	Official TWSE-style ownership-change filing independently confirms a 2019 share transfer for ABC Trading Co Ltd, with filing date and share count matching the client's narrative of the prior business stake sale. This is a third-party regulatory record, not client-submitted paperwork, so confidence is raised substantially from 72.
2026-08-20 06:51	93%	corroborated	Independent TWSE-style ownership-change filing confirms the 2019 share transfer for ABC Trading Co Ltd, with filing date and share count matching the client's narrative, providing third-party corroboration beyond client-submitted paperwork.

Salary income, textile trading, 2014–2019

S$9,000,000 claimed

When	Confidence	Status	Note
2026-08-19 11:19	0%	pending	No evidence submitted yet.
2026-08-20 06:43	62%	corroborated	Employer-submitted income records for 2015-2019 corroborate the claimed salary income and savings accumulation, providing independent third-party support for the textile trading salary claim (2014-2019 window mostly covered). Confidence is capped at moderate levels since it's a single employer-provided record without cross-verification against tax filings or bank statements.

Brokerage account transfers, 2019–2021

S$6,000,021 claimed

When	Confidence	Status	Note
2026-08-19 11:19	0%	pending	No evidence submitted yet.

Aggregate check — claimed sources vs actual assets

Claimed sources total S$27,000,021 against total assets of S$32,000,000. A gap of S$4,999,979 has no claimed source, independent of any single claim's status.