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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. 4 document(s) submitted to date.

Ownership document 2026-08-08 05:21 UTC

ACRA business profile extract, 2024: Priya Sharma holds a 15% direct equity stake in Meridian Textiles Pte Ltd. Bank onboarding file: identity verification confirms National ID S8512345A, date of birth 14 February 1985, for client Priya Sharma — matches the record on file. ACRA business profile extract, 2024: Priya Sharma holds a 100% equity stake in Sharma Holdings Pte Ltd. Sharma Holdings Pte Ltd holds a 65% equity stake in Meridian Textiles Pte Ltd. Corporate intelligence search result: an individual named Daniel Koh is registered as holding an 8% stake in Meridian Textiles Pte Ltd, but is reported by industry contacts to be acting as a nominee for Priya Sharma — this has not been confirmed through primary documentation.

Identifiers were withheld before this was sent to the AI

ACRA business profile extract, 2024: Priya Sharma holds a 15% direct equity stake in Meridian Textiles Pte Ltd. Bank onboarding file: identity verification confirms National ID [NATIONAL-ID-REDACTED], date of birth [DATE-OF-BIRTH-REDACTED], for client Priya Sharma — matches the record on file. ACRA business profile extract, 2024: Priya Sharma holds a 100% equity stake in Sharma Holdings Pte Ltd. Sharma Holdings Pte Ltd holds a 65% equity stake in Meridian Textiles Pte Ltd. Corporate intelligence search result: an individual named Daniel Koh is registered as holding an 8% stake in Meridian Textiles Pte Ltd, but is reported by industry contacts to be acting as a nominee for Priya Sharma — this has not been confirmed through primary documentation.

date of birth: matched Priya Sharma on file

national id: matched Priya Sharma on file

SoW evidence 2026-08-08 05:42 UTC

ACRA deregistration filing, 2018: confirms Priya Sharma sold her stake in a prior textile trading business for SGD 12,000,000, consistent with the claimed sale.

SoW evidence 2026-08-08 05:42 UTC

Employer HR records confirm salary payments to Priya Sharma consistent with the claimed role and period, 2014-2019.

SoW evidence 2026-08-08 05:42 UTC

Brokerage statements show transfers into Priya Sharma's account in 2019-2021, but the dates precede the confirmed 2018 stake sale that was claimed as the source of these funds — the timing is inconsistent with the stated source.

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

80.0% confirmed

AML Act — 25% threshold

80.0% potential

Escalated for human review

Potential aggregate control (80.0%) crosses the 25% UBO threshold pending confirmation of inferred relationships. No automated action closes this case.

RelationshipStatusRationaleRecorded
Priya Sharma → Meridian Textiles Pte Ltd (15% direct) verified ACRA business profile extract 2024 states Priya Sharma holds a 15% direct equity stake in Meridian Textiles Pte Ltd. 2026-08-08 05:22
Priya Sharma → Sharma Holdings Pte Ltd (100% direct) verified ACRA business profile extract 2024 states Priya Sharma holds a 100% equity stake in Sharma Holdings Pte Ltd. 2026-08-08 05:22
Sharma Holdings Pte Ltd → Meridian Textiles Pte Ltd (65% direct) verified ACRA business profile extract 2024 states Sharma Holdings Pte Ltd holds a 65% equity stake in Meridian Textiles Pte Ltd. 2026-08-08 05:22
Daniel Koh → Meridian Textiles Pte Ltd (8% registered direct) verified Corporate intelligence search confirms Daniel Koh is registered as holding an 8% stake in Meridian Textiles Pte Ltd. 2026-08-08 05:22
Daniel Koh → Priya Sharma (suspected nominee for) inferred Industry contacts report Daniel Koh may be acting as a nominee for Priya Sharma's registered 8% stake, but this is unconfirmed by primary documentation. 2026-08-08 05:22

How the ownership structure was uncovered

2026-08-08 05:22 UTC
ACRA filings confirm Priya Sharma's direct 15% stake in Meridian Textiles and reveal a new holding vehicle, Sharma Holdings Pte Ltd (100% owned by Sharma), which itself holds 65% of Meridian Textiles — significantly raising her aggregate control. Identity checks corroborate this is the same Priya Sharma on file. A corporate intelligence search also flags Daniel Koh's registered 8% stake in Meridian Textiles as a possible undisclosed nominee position for Sharma, which remains unconfirmed and is logged as an inferred link pending primary documentation.

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

Sale of prior business stake, 2018

S$12,000,000 claimed — Sold my prior business stake in 2018.

WhenConfidenceStatusNote
2026-08-08 05:41 0% pending No evidence submitted yet.
2026-08-08 05:42 78% corroborated Official ACRA deregistration filing independently confirms the sale of a prior textile trading business stake in 2018 for SGD 12,000,000, matching the claim's timing and nature; confidence is not higher because the exact valuation/counterparty details and use of proceeds are not independently verified.

Salary income, textile trading, 2014–2019

S$9,000,000 claimed — Salary income from textile trading role, 2014-2019.

WhenConfidenceStatusNote
2026-08-08 05:41 0% pending No evidence submitted yet.
2026-08-08 05:42 75% corroborated Independent third-party employer HR records confirm salary payments consistent with the claimed role and period (2014-2019), directly corroborating the claim.

Brokerage account transfers, 2019–2021

S$6,000,000 claimed — Transfers into my brokerage account, 2019-2021.

WhenConfidenceStatusNote
2026-08-08 05:41 0% pending No evidence submitted yet.
2026-08-08 05:42 15% downgraded Brokerage statements confirm transfers occurred in 2019-2021, but the timing conflicts with the claimed source (2018 stake sale) — transfers reportedly precede or misalign with the sale proceeds, undermining the stated causal link between the two claims.

Aggregate check — claimed sources vs actual assets

Claimed sources total S$27,000,000 against total assets of S$32,000,000. A gap of S$5,000,000 has no claimed source, independent of any single claim's status.