Counterparty Vetting Report

Overview

A Counterparty Vetting Report is a paginated, twelve-section due-diligence document on one transaction counterparty — an entity (company, fund, trust, NGO, government supplier) or an individual (principal, director, beneficial owner, sole proprietor). It is generated on demand from public registry filings, sanctions / PEP / adverse-media surfaces, regulatory enforcement records, and the counterparty's own enriched profile. It takes three to five minutes to produce, costs 50 credits (about $20 USD), and is delivered as a shareable HTML report with a printable PDF view.

It is intended for a corporate development team evaluating an M&A target or supplier, a PE/VC partner doing pre-close Due Diligence, a hedge fund evaluating a counterparty, a sanctions / AML compliance officer screening a new account, a lender evaluating a borrower, or a government-contractor compliance lead checking a subcontractor.

The report is not a verdict on the counterparty. It is a structured presentation of the public record for the buyer-side compliance / commercial team to evaluate themselves against AML/KYC, sanctions, FCPA, and counterparty-risk standards. Every claim cites a public URL or is flagged as insufficient evidence. Every probability is expressed in the seven-band UK PHIA Yardstick vocabulary plus an analytical-confidence rating.

The Five Frameworks We Adopt

AML/KYC — FATF, BSA, FinCEN, EU AMLD5/6

Anti-Money-Laundering and Know-Your-Customer compliance. The Financial Action Task Force (FATF) Recommendations are the global standard. The U.S. Bank Secrecy Act and FinCEN guidance implement them domestically. The EU's AMLD5 and AMLD6 directives implement them across EU member states, with national-level legislation (UK MLR 2017 as amended; Germany's GwG; etc.). FATF Recommendation 12 specifically governs PEP screening obligations.

OFAC Sanctions Compliance

The U.S. Treasury Department's Office of Foreign Assets Control administers economic sanctions including the Specially Designated Nationals (SDN) list, country-specific sanctions regimes (Russia / Iran / Cuba / DPRK / Venezuela / Syria / etc.), sectoral sanctions, and secondary sanctions. OFAC enforcement reach extends to non-U.S. counterparties via secondary sanctions and to U.S. persons globally. Section 5 (Sanctions Screening — Full) screens against OFAC SDN plus UN, EU, and UK consolidated lists.

FCPA Framework

The U.S. Foreign Corrupt Practices Act (15 U.S.C. § 78dd-1 et seq.) prohibits payments to foreign officials to obtain or retain business. The U.K. Bribery Act 2010 and Brazil's Clean Companies Act provide analogous frameworks in their jurisdictions. Section 8 (FCPA Compliance Signals) maps the counterparty's exposure to foreign corruption risk: high-CPI-risk jurisdictions, government counterparties, prior DOJ / SEC FCPA enforcement.

ICD 203 — Analytic Standards (Office of the Director of National Intelligence)

The U.S. Intelligence Community's Directive 203 defines nine tradecraft standards: properly described sources, proper expression of uncertainty, distinction between intelligence and assumptions, incorporation of alternative analysis, judgement of consequences, customer-relevant focus, logical argumentation, accurate reflection of source content, and clear language. We treat these as binding for every Counterparty Vetting Report.

UK PHIA Probability Yardstick (UK Defence Intelligence)

The Professional Head of Intelligence Assessment publishes a seven-band probability yardstick — Remote chance (under 5%) / Highly unlikely (10-20%) / Unlikely (25-35%) / Realistic possibility (40-50%) / Likely (55-75%) / Highly likely (80-90%) / Almost certain (over 95%). Every probabilistic claim — sanctions-proximity inferences, beneficial-owner opacity claims, FCPA-exposure projections — is expressed using these seven bands paired with a separate analytical-confidence rating (High / Moderate / Low).

The Twelve Sections of a Counterparty Vetting Report

AML/KYC — How We Apply It

Anti-money-laundering and know-your-customer compliance is the central methodology body for counterparty Due Diligence. Three frameworks define the practice:

• FATF Recommendations. The Financial Action Task Force is the inter-governmental body that sets the global AML/CFT standard. Recommendations 10-12 (customer due diligence; PEPs; record-keeping) are the practitioner-relevant core. Recommendation 12 specifically requires enhanced due diligence on PEPs, their family members, and close associates.
• U.S. Bank Secrecy Act + FinCEN guidance. The BSA (and its Patriot Act amendments) implement FATF in the U.S. financial system. FinCEN's Customer Due Diligence Rule (effective 2018) requires identification of beneficial owners (25%+ equity owners + a single control person) for legal-entity customers.
• EU AMLD5 / AMLD6. The Fifth and Sixth Anti-Money-Laundering Directives implement FATF in the EU, with public beneficial-ownership registries, expanded virtual-currency coverage, and harmonised criminal sanctions for money-laundering offences.

Sections 3 (Identity & Beneficial Ownership), 5 (Sanctions Screening — Full), 6 (PEP Screening), and 7 (Adverse Media Pattern) of every Counterparty Vetting Report apply these frameworks directly to the counterparty's public record. Where evidence on any axis is genuinely thin, the section writes "[insufficient public evidence as of date]" rather than fabricating. PHIA bands carry the inference where it is possible to make one.

Sanctions — Lists Screened

Section 5 (Sanctions Screening — Full) screens the counterparty (and, for entities, their parents and named UBOs) against four publicly-available consolidated lists. Each is labelled with status (clean / flagged), PHIA confidence band, and a citation to the primary source as of report-generation date.

• OFAC Specially Designated Nationals (SDN) list — U.S. Treasury Department / OFAC. Updated continuously.
• UN Security Council Consolidated Sanctions List — UN Security Council / 1267 Committee + sanctions committees.
• EU Financial Sanctions consolidated list — Council of the European Union / European External Action Service.
• UK HMT Consolidated List of financial sanctions targets — HM Treasury / Office of Financial Sanctions Implementation.

What we do NOT screen against: subscription consolidated-screening tools (World-Check, LexisNexis WorldCompliance, Dow Jones Risk & Compliance, ComplyAdvantage), country-specific sub-lists not consolidated above, sectoral sanctions matrices that require deal-context scoring, or secondary-sanctions exposure under U.S. extraterritorial regimes (those require deal-specific legal analysis we do not provide).

We disclose this honestly in every Section 5 output: "Subscription consolidated-screening tools not consulted; this screen relies on publicly-available list versions only."

FCPA & Foreign-Corruption Frameworks

The U.S. Foreign Corrupt Practices Act (15 U.S.C. § 78dd-1 et seq.) prohibits U.S. persons and U.S.-listed companies from paying foreign officials to obtain or retain business. Two analogous frameworks have global reach:

• U.K. Bribery Act 2010. Broader than FCPA in some respects (covers private-sector bribery; strict liability for failure to prevent bribery). U.K. Serious Fraud Office (SFO) enforcement.
• Brazil's Clean Companies Act (Lei Anticorrupção, 2013). Civil and administrative liability for corporate bribery, broad jurisdictional reach within Brazil.

Section 8 (FCPA Compliance Signals) of every Counterparty Vetting Report maps the counterparty's exposure to foreign-corruption risk along three axes:

1. Jurisdictional risk. Subsidiaries, joint ventures, or sourcing from countries scoring poorly on the Transparency International Corruption Perceptions Index. Joint ventures with state-owned enterprises in those jurisdictions.
2. Government-counterparty exposure. Sales to foreign government entities, regulatory permits required to operate in foreign markets, public-procurement-sourced revenue.
3. Prior enforcement history. DOJ FCPA enforcement releases, SEC FCPA cease-and-desist orders, U.K. SFO press releases, deferred-prosecution agreements naming the counterparty or its parent.

If a counterparty has prior FCPA exposure, that is surfaced with severity tier and citation. If clean: "No FCPA-exposure signals identified after extensive search of DOJ FCPA enforcement releases, SEC enforcement actions, U.K. SFO press, and equivalent foreign regulators as of [date]."

Honest Limits — what we do not do

Corrections Policy

Three commitments modeled on the BBC editorial corrections process:

1. Identification window. Errors flagged within thirty days of report generation are corrected on the canonical view URL within five business days. Errors flagged after thirty days are evaluated and corrected at our discretion.
2. Re-publication, not silent edit. Corrections do not overwrite the prior text silently. The report's view page preserves a redline diff between the original and corrected text, time-stamped, with a one-line explanation.
3. Subject right of reply. The counterparty named in any Vetting Report may submit a one-paragraph factual rebuttal to corrections@mentionfox.com. Verifiable rebuttals attach to the report alongside the original section. Where the counterparty and our research disagree on a public-record claim, both views are surfaced.

Data integrity floor — ALCOA. Every Counterparty Vetting Report carries an ALCOA Methodology footer: each factual claim is Attributable to a cited source, presented in Legible plain language, marked with the date it was Contemporaneously verified, sourced from the Original primary record where available, and Accurately reflects the underlying evidence with explicit uncertainty flags where evidence is thin.