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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 22:06 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 06:01 UTC

MOEA company registry filing, 2024: shareholder register for Golden Harvest Foods Co Ltd lists Chen Li-Wen holding a 5% direct equity stake. 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. Hong Kong Companies Registry annual return, 2024: Li-Wen Chen holds a 60% equity stake in Pacific Rim Holdings Ltd. Hong Kong Companies Registry annual return, 2024: Pacific Rim Holdings Ltd holds a 30% equity stake in Golden Harvest Foods Co Ltd. 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. 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

MOEA company registry filing, 2024: shareholder register for Golden Harvest Foods Co Ltd lists Chen Li-Wen holding a 5% direct equity stake. 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. Hong Kong Companies Registry annual return, 2024: Li-Wen Chen holds a 60% equity stake in Pacific Rim Holdings Ltd. Hong Kong Companies Registry annual return, 2024: Pacific Rim Holdings Ltd holds a 30% equity stake in Golden Harvest Foods Co Ltd. 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. 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

SoW evidence 2026-08-08 06:02 UTC

Company annual reports and dividend payment records confirm dividend distributions to Chen Li-Wen consistent with the claimed amounts and period, 2016-2022. 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.

SoW evidence 2026-08-08 06:03 UTC

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.

SoW evidence 2026-09-08 08:07 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.

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.

RelationshipStatusRationaleRecorded
Chen Li-Wen → Golden Harvest Foods Co Ltd (5% direct) verified MOEA company registry shareholder filing lists Chen Li-Wen holding 5% direct equity stake. 2026-08-08 06:01
Chen Li-Wen → Pacific Rim Holdings Ltd (60% direct) verified Hong Kong Companies Registry annual return 2024 lists Li-Wen Chen (matched to Chen Li-Wen) holding 60% equity stake. 2026-08-08 06:01
Pacific Rim Holdings Ltd → Golden Harvest Foods Co Ltd (30% direct) verified Hong Kong Companies Registry annual return 2024 states Pacific Rim Holdings Ltd holds 30% equity stake in Golden Harvest Foods Co Ltd. 2026-08-08 06:01
Pacific Rim Holdings Ltd → Silverline Capital Ltd (beneficial link (unconfirmed)) inferred Corporate intelligence search reports a beneficial link between Pacific Rim Holdings Ltd and Silverline Capital Ltd, not confirmed by primary documentation. 2026-08-08 06:01
Silverline Capital Ltd → Golden Harvest Foods Co Ltd (15% direct) verified BVI Registry extract 2024 shows Silverline Capital Ltd holds 15% equity stake in Golden Harvest Foods Co Ltd. 2026-08-08 06:01

How the ownership structure was uncovered

2026-08-08 06:01 UTC
Confirmed 'Li-Wen Chen' as a name variant of Chen Li-Wen via matching national ID/DOB in private banking onboarding file. New registry filings reveal Chen Li-Wen holds 5% direct in Golden Harvest Foods and 60% in newly identified Pacific Rim Holdings Ltd (HK), which itself holds 30% of Golden Harvest. A new entity, Silverline Capital Ltd (BVI), holds a verified 15% stake in Golden Harvest and has an unconfirmed intelligence-sourced beneficial link to Pacific Rim Holdings, flagged as inferred pending primary documentation.

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

Dividend income from family manufacturing business, 2016–2022

NT$28,000,000 claimed

WhenConfidenceStatusNote
2026-08-08 06:01 0% pending No evidence submitted yet.
2026-08-08 06:02 85% corroborated Independent third-party evidence (company annual reports and dividend payment records) confirms dividend distributions to Chen Li-Wen matching the claimed amounts and period 2016-2022, providing strong corroboration.
2026-09-08 08:07 85% corroborated This filing pertains to a 2019 share transfer, not to dividend income from the family manufacturing business (2016-2022). It does not independently corroborate or conflict with the dividend income claim, so confidence remains unchanged.

Sale of Taichung commercial property, 2020

NT$18,000,000 claimed

WhenConfidenceStatusNote
2026-08-08 06:01 0% pending No evidence submitted yet.
2026-08-08 06:03 35% downgraded Official land registry record independently confirms the property sale occurred in Taichung in 2020, corroborating that the transaction took place; however, the declared sale price of NT$11,000,000 is materially below the NT$18,000,000 claimed, a discrepancy of ~39% that undermines the claimed magnitude of proceeds as a source of wealth. This inconsistency warrants a downgrade pending clarification of the price gap.
2026-09-08 08:07 35% downgraded The filing concerns a 2019 share transfer of ABC Trading Co Ltd, which is unrelated to the claimed 2020 sale of a Taichung commercial property. It does not provide independent corroboration for this real estate sale claim, so the existing downgraded status and confidence stand.

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.