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 21:49 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. 3 document(s) submitted to date.
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.
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.
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 |
|---|---|---|---|
| Wei-Chen L. → W.C. Lin Family Trust (possible trust beneficiary (unconfirmed)) | inferred | Offshore registry cross-search suggests Wei-Chen L. may be a beneficiary of the W.C. Lin Family Trust, but no trust deed has been produced to confirm this. | 2026-08-20 05:56 |
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 |
|---|---|---|---|
| 2026-08-12 06:24 | 0% | pending | No evidence submitted yet. |
| 2026-08-20 05:56 | 20% | pending | This filing documents a 2019 share transfer for ABC Trading Co Ltd, which relates to a share sale event, not to dividend income from the family manufacturing business over 2016–2022. It does not independently corroborate the dividend income claim, so confidence remains low/unchanged. |
Sale of Taichung commercial property, 2020
NT$18,000,000 claimed
| When | Confidence | Status | Note |
|---|---|---|---|
| 2026-08-12 06:24 | 0% | pending | No evidence submitted yet. |
| 2026-08-20 05:56 | 15% | pending | The document is a TWSE-style ownership-change filing concerning share transfer in ABC Trading Co Ltd, not the sale of a Taichung commercial property. There is no property registry, deed, or transaction record referencing real estate, so it does not corroborate this claim; it may in fact point to a different, previously undisclosed source-of-wealth event (a 2019 share sale) that should be reconciled with the client's overall narrative. |
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.