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 22:00 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. 4 document(s) submitted to date.

Ownership document 2026-08-12 06:25 UTC

MOEA/GCIS company registration extract, 2024 — Business_Accounting_NO: 70556219, Company_Name: Golden Harvest Foods Co Ltd, Company_Status: 01 (核准設立 — Approved/Registered). Shareholder register (bank-obtained, not part of the GCIS extract itself) 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/GCIS company registration extract, 2024 — Business_Accounting_NO: 70556219, Company_Name: Golden Harvest Foods Co Ltd, Company_Status: 01 (核准設立 — Approved/Registered). Shareholder register (bank-obtained, not part of the GCIS extract itself) 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 2026-08-12 06:27 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 2026-08-18 03:38 UTC

Property registry search, Taipei property: title has been held under a different registered owner since 2016. This is inconsistent with the client's claimed rental income from this property; the client-submitted lease copy does not reconcile with registry records.

Ownership document 2026-08-20 06:51 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

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.

Relationship	Status	Rationale	Recorded
Chen Li-Wen → Golden Harvest Foods Co Ltd (5% direct)	verified	Bank-obtained shareholder register lists Chen Li-Wen as holding 5% direct equity in Golden Harvest Foods Co Ltd.	2026-08-12 06:25
Chen Li-Wen → Pacific Rim Holdings Ltd (60% direct)	verified	Hong Kong Companies Registry 2024 annual return shows Li-Wen Chen (matched to Chen Li-Wen via ID/DOB) holding 60% equity in Pacific Rim Holdings Ltd.	2026-08-12 06:25
Pacific Rim Holdings Ltd → Golden Harvest Foods Co Ltd (30% direct)	verified	Hong Kong Companies Registry 2024 annual return shows Pacific Rim Holdings Ltd holding 30% equity in Golden Harvest Foods Co Ltd.	2026-08-12 06:25
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.	2026-08-12 06:25
Silverline Capital Ltd → Golden Harvest Foods Co Ltd (15% direct)	verified	BVI Registry extract 2024 shows Silverline Capital Ltd holding 15% equity in Golden Harvest Foods Co Ltd.	2026-08-12 06:25

How the ownership structure was uncovered

2026-08-12 06:25 UTC

MOEA/GCIS registration confirms Golden Harvest Foods Co Ltd is active; bank-obtained register and HK/BVI registry filings reveal a layered ownership chain: Chen Li-Wen holds 5% direct in Golden Harvest and separately holds 60% of Pacific Rim Holdings Ltd (HK), which itself holds 30% of Golden Harvest, aggregating Chen's effective control. Pacific Rim also has an unconfirmed intelligence-sourced beneficial link to BVI entity Silverline Capital Ltd, which per BVI registry holds a further 15% direct stake in Golden Harvest — flagged as inferred pending primary documentation.

2026-08-12 06:26 UTC

Checked 'Chen Li-Wen' 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: 'Chien, Wen-Li' (Entity node extracted from the Offshore Leaks data., similarity 91.7/100); 'Chen Li Mei' (Entity node extracted from the Offshore Leaks data., similarity 81.8/100); 'Chiu, Wen-Chen' (Entity node extracted from the Offshore Leaks data., similarity 76.9/100).

2026-08-12 06:26 UTC

Checked 'Golden Harvest Foods Co Ltd' 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: 'Grand Harvest Foods Co., Ltd.' (Entity node extracted from the Panama Papers data., similarity 81.5/100); 'COPPER HARVEST FOODS LTD.' (Entity node extracted from the Paradise Papers - Nevis corporate registry data., similarity 63.0/100); 'GOLDEN HARVEST HOLDINGS DEVELOPMENT CO., LTD.' (Entity node extracted from the Panama Papers data., similarity 54.8/100).

2026-08-17 06:03 UTC

Checked 'Silverline Capital Ltd' 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: 'SILVERLINE GROUP LTD.' (Entity node extracted from the Bahamas Leaks data., similarity 68.2/100); 'Capital Premier Ltd.' (Entity node extracted from the Offshore Leaks data., similarity 63.6/100); 'SILVERLINE INVESTMENTS LTD.' (Entity node extracted from the Bahamas Leaks data., similarity 61.5/100).

2026-08-17 08:25 UTC

2026-08-20 06:51 UTC

Employer verification record introduces a new individual 'Lin Wei-Chen' (surname-first romanization) as shareholder, cross-matched via ID/DOB to a 'Wei-Chen L.' onboarding record for a previously unseen entity, ABC Trading Co Ltd. Neither individual nor company matches any known entity in this case (ID/DOB comparison against case-file records returned no match), and no ownership stake or percentage is stated in this document, so no edges are recorded. Both are logged as new entities for potential future linkage."

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.
2026-08-12 06:27	82%	corroborated	Independent third-party evidence (company annual reports and dividend payment records) confirms dividend distributions to Chen Li-Wen matching the claimed amounts and 2016-2022 period.

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.
2026-08-12 06:27	30%	downgraded	Land registry record independently confirms the 2020 sale occurred but the declared sale price (NT$11,000,000) is significantly lower than the claimed NT$18,000,000, creating a material discrepancy in claimed source-of-wealth value.
2026-08-18 03:38	8%	downgraded	Property registry search pertains to a Taipei property (different owner since 2016), not the Taichung commercial property sale claim, but reveals a significant discrepancy pattern: client-submitted lease/property documentation does not reconcile with official registry records. This raises broader concerns about the reliability of client-submitted property-related documents used to support source-of-wealth claims, further undermining confidence in the Taichung property sale claim which itself has not been independently corroborated by any land registry or transaction record.

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.