Executive Vetting Report

Overview

An Executive Vetting Report is a paginated, twelve-section due-diligence document on one senior executive being considered for a C-suite hire, board appointment, or PE-portfolio operating-partner role. It is generated on demand from the executive's public role history, SEC filings (Form 4, 10-K, proxy disclosures), regulatory enforcement records, peer coverage, and the subject'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-board director vetting a CEO candidate, a PE/VC partner evaluating an operating-partner hire, a family office vetting a senior operator for a portfolio company, or a search firm building a bench file ahead of placement.

The report is not a verdict on the executive. It is a structured presentation of the public record for the hiring committee to evaluate themselves. 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. Every error identified within thirty days of publication is corrected, re-published, and the redline is preserved.

The Four Frameworks We Adopt

MentionFox / Verifierce Executive Vetting Reports align with four published standards drawn from the U.S. intelligence community, the directors-and-officers underwriting industry, anti-money-laundering compliance, and U.K. defence intelligence.

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 Executive Vetting Report.

D&O Underwriter Risk Framework

Directors-and-officers liability insurance underwriters at Chubb, AIG, Allianz, Travelers, and the major reinsurers evaluate executives along a multi-axis risk framework before binding policies. The framework emphasises: tenure pattern (multiple short stays = elevated risk), Form 4 stock-sale timing relative to material announcements, related-party transactions disclosed in 10-K and proxy filings, prior litigation naming the executive personally, regulatory enforcement actions, board-resignation patterns under stress. Section 5 (Financial Integrity Signals) of every Executive Vetting Report applies this framework directly to the subject's public record.

AML/KYC — Sanctions & PEP Screening

Anti-Money-Laundering and Know-Your-Customer compliance frameworks (Bank Secrecy Act, FinCEN guidance, the Financial Action Task Force standards, EU AMLD5/6) require institutions to screen senior executives against sanctions lists (OFAC SDN list, EU consolidated list, UK HMT list, UN sanctions list) and Politically-Exposed-Person (PEP) databases. Section 11 (Red Flags — Severity-Ranked) screens against publicly-available portions of these lists. We do not have access to subscription-only PEP databases (World-Check, LexisNexis WorldCompliance) and disclose this honestly.

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 in a MentionFox Executive Vetting Report — tenure-pattern claims, Form-4 timing inferences, retention-rate projections, governance-style assessments — is expressed using these seven bands, paired with a separate analytical-confidence rating (High / Moderate / Low).

The Twelve Sections of an Executive Vetting Report

D&O Underwriter Risk Framework — How We Apply It

Directors-and-officers liability insurance pricing is one of the most demanding executive risk-evaluation processes in the U.S. economy. Underwriters at Chubb, AIG, Allianz, Travelers, and the major reinsurance markets evaluate every candidate executive against a multi-axis framework before binding new D&O policies, raising premiums, or excluding individuals from coverage. The same framework translates cleanly to pre-hire vetting because it asks the same question hiring boards ask: what is the probability this executive becomes a costly governance event in the next five years?

Section 5 (Financial Integrity Signals) of every Executive Vetting Report applies this framework along five axes:

1. Compensation pattern. Cash-vs-equity mix where disclosed in proxy filings. Repricing events (SEC-disclosed equity grant repricings are a yellow flag for governance risk). Golden-parachute trigger structure. Perks materially above peer median.
2. Form 4 timing. Stock sales within the 30-day window before negative material announcements (earnings misses, FDA setbacks, regulatory actions, accounting restatements, executive departures). Cluster patterns of executive selling around predictable events. Pledging or hedging of company stock where company policy bans it.
3. Related-party transactions. 10-K and proxy disclosures of business arrangements between the executive (or their family / affiliated entities) and the company. Volume, terms relative to arms-length pricing, recurrence pattern.
4. Litigation exposure. Civil suits naming the executive personally as defendant. Securities class actions where the executive is named. Settlement patterns. Insurance-recoverable vs personal-liability exposure.
5. Regulatory enforcement. SEC, FTC, DOJ, FINRA, state-AG enforcement actions. Wells notices. Consent decrees. Sarbanes-Oxley certification disputes.

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. We do not access D&O underwriting databases directly (those are subscription products of the underwriters themselves); we apply the framework's logic to the public record.

AML/KYC — Sanctions & PEP Screening

Anti-money-laundering and know-your-customer compliance is the second body of evaluation methodology we adopt. The Bank Secrecy Act, FinCEN guidance, the Financial Action Task Force (FATF) Recommendations, and the EU's AMLD5 / AMLD6 directives require regulated institutions to screen senior counterparties against:

• Sanctions lists. OFAC Specially Designated Nationals (SDN) list, EU consolidated list of persons subject to financial sanctions, UK HMT consolidated list, UN Security Council sanctions lists, country-specific sanctions regimes.
• Politically-Exposed-Person (PEP) status. Heads of state, senior politicians, judiciary, military leadership, state-owned-enterprise executives, plus their immediate family and close business associates. PEP status is not itself a red flag but elevates due-diligence requirements.
• Adverse media. Negative press coverage in last 5 years across major outlets, fraud-allegation reporting, regulatory-investigation reporting.

Section 11 (Red Flags — Severity-Ranked) of every Executive Vetting Report screens the subject against the publicly-available portions of OFAC SDN, EU consolidated, UK HMT, and UN sanctions lists. We do not have access to subscription PEP databases (World-Check, LexisNexis WorldCompliance, Dow Jones Risk & Compliance, ComplyAdvantage), and we disclose this honestly. When PEP screening matters to the hiring decision, the buyer should commission a CRA-tier screening from a vendor with database access.

FCRA Limits — what this report cannot be used for

Honest limits beyond FCRA

• We do not access subscription PEP databases (World-Check, LexisNexis WorldCompliance, Dow Jones, ComplyAdvantage).
• We do not access sealed legal records, juvenile records, or expunged records.
• We do not access the subject's personal financial records, undisclosed transactions, or private communications.
• We do not call references on the subject's behalf or interview former colleagues — that is human reference-check work, separate from this report.
• We do not run credit checks, criminal-background checks (per state-specific FCRA requirements), or drug-screening.
• We do not invent claims to fill thin sections; "[insufficient public evidence as of date]" is the honest fallback.

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. Any reader who saw the original can audit the change.
3. Subject right of reply. The executive 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 executive and our research disagree on a public-record claim, both views are surfaced; we do not silently capitulate, and we do not refuse to publish the executive's view.

Data integrity floor — ALCOA. Every Executive 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. ALCOA is the U.S. Food and Drug Administration's data-integrity principle for regulated industries; we adopt it as the floor for synthesis research because it captures the same disciplines without the regulatory overhang.