AI decision audit trail
Grace Lim — Lim Family Ventures 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 22:00 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. 5 document(s) submitted to date.
ACRA business profile extract, 2024: Grace Lim holds a 40% direct equity stake in Lim Family Ventures Pte Ltd. Bank onboarding file: identity verification confirms National ID S8034567C, date of birth 15 June 1980, for client Grace Lim — matches the record on file.
Identifiers were withheld before this was sent to the AI
ACRA business profile extract, 2024: Grace Lim holds a 40% direct equity stake in Lim Family Ventures Pte Ltd. Bank onboarding file: identity verification confirms National ID [NATIONAL-ID-REDACTED], date of birth [DATE-OF-BIRTH-REDACTED], for client Grace Lim — matches the record on file.
date of birth: matched Grace Lim on file
national id: matched Grace Lim on file
ACRA share transfer filing, 2018: records the transfer of Grace Lim's shares in Lim Logistics Pte Ltd for a consideration of SGD 15,000,000, consistent with the claimed sale. IRAS notice of assessment records, 2012-2020: reported employment income figures are consistent with the salary and bonus amounts claimed. Grant of probate, Singapore Family Justice Courts, 2015: total estate distributed to Grace Lim recorded as SGD 2,300,000 — materially less than the SGD 6,000,000 claimed, with no explanation on file for the difference. Personal brokerage account statements (client-submitted) show portfolio activity consistent with the claimed gains, but the statements have not been independently verified against brokerage or tax records.
IRAS notice of assessment records, 2012-2020: reported employment income figures are consistent with the salary and bonus amounts claimed.
Grant of probate, Singapore Family Justice Courts, 2015: total estate distributed to Grace Lim recorded as SGD 2,300,000 — materially less than the SGD 6,000,000 claimed, with no explanation on file for the difference.
Personal brokerage account statements (client-submitted) show portfolio activity consistent with the claimed gains, but the statements have not been independently verified against brokerage or tax records. Expected result: claim 1 corroborate
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
40.0% confirmed
AML Act — 25% threshold
40.0% potential
Escalated for human review
Potential aggregate control (40.0%) crosses the 25% UBO threshold pending confirmation of inferred relationships. No automated action closes this case.
| Relationship | Status | Rationale | Recorded |
|---|---|---|---|
| Grace Lim → Lim Family Ventures Pte Ltd (40% direct) | verified | ACRA business profile extract states Grace Lim holds a 40% direct equity stake in Lim Family Ventures Pte Ltd. | 2026-08-08 09:29 |
How the ownership structure was uncovered
Source-of-wealth claims — how confidence changed over time
Sale of family business stake, 2018
S$15,000,000 claimed
| When | Confidence | Status | Note |
|---|---|---|---|
| 2026-08-08 09:29 | 0% | pending | No evidence submitted yet. |
| 2026-08-08 09:29 | 88% | corroborated | ACRA share transfer filing is an official third-party government record confirming the SGD 15,000,000 sale consideration for Grace Lim's shares in Lim Logistics Pte Ltd, consistent with the claimed 2018 family business stake sale. |
| 2026-08-08 09:30 | 88% | corroborated | Client-submitted brokerage statements show activity consistent with the claimed sale proceeds, but as they are self-submitted and not independently verified against brokerage or tax authority records, they do not add incremental corroboration beyond the existing confirmed status; confidence held at prior level rather than increased. |
Salary and bonus income, senior executive role, 2012–2020
S$9,000,000 claimed
| When | Confidence | Status | Note |
|---|---|---|---|
| 2026-08-08 09:29 | 0% | pending | No evidence submitted yet. |
| 2026-08-08 09:30 | 78% | corroborated | IRAS notice of assessment is an official third-party tax authority record spanning 2012-2020 that independently confirms reported employment income figures match the claimed salary and bonus amounts, providing strong external corroboration. |
Inheritance from maternal grandmother, 2015
S$6,000,000 claimed
| When | Confidence | Status | Note |
|---|---|---|---|
| 2026-08-08 09:29 | 0% | pending | No evidence submitted yet. |
| 2026-08-08 09:30 | 30% | downgraded | Official probate record confirms an inheritance occurred but the distributed estate value (SGD 2.3M) is materially less than the SGD 6M claimed, with no explanation for the discrepancy, so the claim as stated is not fully supported and warrants downgrade pending clarification. |
Aggregate check — claimed sources vs actual assets
Claimed sources total S$30,000,000 against total assets of S$40,000,000. A gap of S$10,000,000 has no claimed source, independent of any single claim's status.