Illustrative. Everything on this page is fictional: Kestrel Freight Ltd, Northgate Holdings Ltd, Daniel Okafor, the analyst Alex, every excerpt, every date and every time. It shows the format of a Sweat AI review. It does not describe a real company, person or customer case.
Sweat AI is an AI-native BPO for banks and fintechs, starting with back-office workflows like KYB, onboarding and fraud reviews. This page walks through one completed KYB review the way your approver would read it, with notes on why each part is there. It uses the same fictional case as our homepage.
The application (illustrative)
Kestrel Freight Ltd, a freight forwarder, applies for a business account with outbound payments. The application names one shareholder above 25 percent, Northgate Holdings Ltd with 60 percent, and a managing director as the control person. It arrives on a Friday evening and goes to the manual review queue because the automated check could not resolve an individual beneficial owner behind the corporate shareholder.
Alex, a KYC analyst at Sweat AI, picks it up overnight.
Summary page
The first thing your approver sees:
| Field | Value (illustrative) |
|---|---|
| Applicant | Kestrel Freight Ltd |
| Product applied for | Business account with outbound payments |
| Analyst | Alex |
| Review completed | Saturday, 02:40 UTC |
| Recommended disposition | Pause pending documents |
| Overall risk | Moderate, pending items 1 to 3 |
| Identity confidence (entity) | High: registry record matches name, number and address |
| Beneficial owners identified | Daniel Okafor, 31.2% indirect through Northgate Holdings Ltd |
| Open requests | 4 items, one consolidated list |
Why this is here: the approver should know the recommendation and the reason before reading anything else. Identity confidence is marked high only because a government registry record supports it; the applicant's own website could not establish that on its own.
Findings
Each finding follows the same shape: what we found, the source excerpt it rests on, when the source was captured, and what the source cannot tell you.
Finding 1: the entity exists and is active
- Finding. Kestrel Freight Ltd is registered, active, and its registered number and registered office match the application.
- Source excerpt (illustrative). "Company status: Active. Incorporated on: 11 March 2019. Registered office address: Unit 4, Harbour Road Industrial Estate."
- Captured. Saturday 01:12 UTC, from the company registry of the applicant's jurisdiction. Content hash recorded.
- Limitation. Registry status reflects filings. It does not show whether the company is trading, and it does not establish who controls it day to day.
Why this is here: the excerpt and capture time let you show later exactly what the registry said when we read it, even if the record changes.
Finding 2: Northgate Holdings Ltd holds 60 percent of Kestrel
- Finding. Kestrel's most recent filed shareholder information lists Northgate Holdings Ltd with 60 percent. The remaining 40 percent is held by two individuals at 20 percent each, both below the 25 percent threshold (names withheld in this sample).
- Source excerpt (illustrative). "Northgate Holdings Ltd: 600 ordinary shares of 1,000 issued."
- Captured. Saturday 01:14 UTC, from Kestrel's latest annual filing on the registry.
- Limitation. The filing is eleven months old. Transfers since then would not appear.
Finding 3: Daniel Okafor holds 52 percent of Northgate, so 31.2 percent of Kestrel indirectly
- Finding. Northgate's filed shareholder information lists Daniel Okafor with 52 percent. Tracing through the chain: 52% × 60% = 31.2 percent indirect ownership of Kestrel.
- Source excerpt (illustrative). "Daniel Okafor: 520 ordinary shares of 1,000 issued."
- Captured. Saturday 01:19 UTC, from Northgate's latest annual filing on the registry.
- Limitation. Also eleven months old. The application did not name Mr. Okafor, so his role was found, not declared.
Why this is here: 31.2 percent is above the 25 percent ownership threshold in the US CDD rule, which counts individuals who own 25 percent or more "directly or indirectly" (31 CFR 1010.230). Your policy sets your threshold; the packet shows the arithmetic so your team can apply it. Some policies also treat a majority holder of an intermediate company as controlling that company's whole stake, so the packet shows both figures: 52 percent of Northgate, and 31.2 percent of Kestrel by multiplication.
| Level (illustrative) | Holder | Holds | Share of Kestrel |
|---|---|---|---|
| Individual | Daniel Okafor | 52% of Northgate Holdings Ltd | 31.2% indirect |
| Shareholder | Northgate Holdings Ltd | 60% of Kestrel Freight Ltd | 60% direct |
| Applicant | Kestrel Freight Ltd |
Finding 4: the control person matches the filings
- Finding. The managing director named on the application is listed as a director of Kestrel in the registry. Mr. Okafor is a director of Northgate and does not appear among Kestrel's officers.
- Source excerpt (illustrative). Kestrel officers list: "Director, appointed 11 March 2019." Northgate officers list: "Daniel Okafor, Director."
- Captured. Saturday 01:22 UTC.
- Limitation. Officer lists show appointments, not who actually runs the business. Identity verification of the control person is performed through your own IDV flow and is not part of this finding.
Finding 5: sanctions screening returned no match on the lists read
- Finding. Kestrel Freight Ltd, Northgate Holdings Ltd and Daniel Okafor were screened by exact name after normalization. No match was recorded on any list read.
- Screening record (illustrative). OFAC SDN (primary and alternate names), UN Security Council Consolidated, UK Sanctions List and EU Consolidated list, each read Saturday 01:30 UTC with rows read and content hash recorded.
- Limitation. A zero-match screen is an observation about those lists on that date. It is not a statement that the subject is unsanctioned, and it does not replace your own screening obligations.
Why this is here: the packet records what was read and when, so a later list update can be checked against the exact version used.
Finding 6: one adverse media hit resolved as a different company
- Finding. One news article (illustrative) describes a court dispute involving "Northgate Holdings". The article gives a different registered number and a different country. Resolved as a different entity.
- Source excerpt (illustrative). "…Northgate Holdings, registration number ending 4471, based in…"
- Captured. Saturday 01:48 UTC. One independent publisher; no syndicated copies.
- Limitation. Media searches cover what is publicly indexed and readable. Absence of further stories is not evidence of absence.
Why this is here: a same-name hit is recorded and resolved in the open, with the identifier that ruled it out, so your approver does not have to redo the search.
Finding 7: the business model matches, the trading address does not
- Finding. Kestrel's website describes road freight forwarding between the UK and continental Europe, consistent with the application. The website's contact page lists a trading address different from the registered office.
- Source excerpt (illustrative). "Visit us: Bay 12, Northfield Logistics Park."
- Captured. Saturday 02:05 UTC, from the applicant's website, bound as a first-party source.
- Limitation. A website is the applicant's own claim. It supports the stated business model; it does not prove operations or address.
Gaps
- The application states expected outbound payments but not the destination countries or monthly volume.
- No filed accounts were readable for the most recent period.
Why this is here: gaps are listed as gaps. Nothing missing is quietly treated as a pass.
The remaining-request list
One list for the applicant, drafted for your team to send. Each item says why it is needed, what counts as acceptable and what it enables.
| # | Request | Why it is needed | Acceptable evidence | What it enables |
|---|---|---|---|---|
| 1 | Current shareholder register of Northgate Holdings Ltd, or a signed ownership declaration dated this month | The only ownership record is eleven months old | Register extract or declaration showing Daniel Okafor's current holding | Confirms the 31.2% indirect figure is still current |
| 2 | Identity verification of Daniel Okafor through your usual flow | He is a beneficial owner above threshold and was not named on the application | A completed check in your IDV tool | Completes beneficial ownership requirements |
| 3 | Proof of the trading address at Bay 12, Northfield Logistics Park | The website lists a different address from the registered office | Lease, utility bill or similar, dated within your policy window, in Kestrel's name | Resolves the address discrepancy |
| 4 | Expected monthly outbound volume and destination countries | Needed to set the expected activity profile | Applicant's written answer | Sets the baseline for ongoing monitoring |
We did not ask for anything we could read ourselves: the certificate of incorporation, officer lists and Kestrel's own shareholder filing were already on the registry.
Recommendation for your decision
Recommended disposition: pause pending documents (illustrative). Reason: a beneficial owner above threshold was identified who was not declared on the application and has not completed identity verification, and the ownership record is eleven months old. If items 1 to 3 arrive and meet the acceptance criteria above, the analyst expects to recommend approval with a condition: review of outbound payment corridors against item 4 after the first 90 days. Prepared by: Alex, KYC analyst, Sweat AI.
Why this is here: the recommendation is one typed field with one reason. A bare "approve" cannot sit next to outstanding checks; that is what "approve with conditions" and "pause" exist for.
The decision is yours. Sweat AI does not approve, decline or onboard anyone. Your approver reads the packet, decides, and records the decision in your system.
What the approver does next
- Reads the summary and the recommendation.
- Opens any finding they want to check and follows the excerpt to the source.
- Decides whether the undeclared beneficial owner changes the risk rating under your policy.
- Sends the request list, edited as they see fit.
- When the applicant replies, the case comes back to us to finish, and the same packet is updated.
Downloadable packet
A completed packet can be saved as a self-contained HTML file with the report text, source excerpts, hashes, capture times, locators, screening records and review status, which your browser can print or save as PDF. Original private documents are not embedded in the export.
Try it on your own applications
This sample is illustrative. The real test is a batch of your own applications. Talk to us about reviewing a first set, see how it works, or read about the full KYB review service and our 24/7 coverage.
Questions
Is Kestrel Freight Ltd a real company?
No. Kestrel Freight Ltd, Northgate Holdings Ltd, Daniel Okafor and the analyst Alex are fictional. Every excerpt, date and time on this page is illustrative and was written to show the format of a review.
Why does the sample recommend a pause and not an approval?
Because a beneficial owner has not yet completed identity verification and the ownership record is eleven months old. A recommendation to approve cannot sit alongside checks that are still outstanding, so the sample pauses pending three specific items and says what would follow once they arrive.
How is the 31.2 percent indirect holding calculated?
Daniel Okafor holds 52 percent of Northgate Holdings Ltd, which holds 60 percent of Kestrel Freight Ltd. Multiplying through the chain gives 0.52 times 0.60, or 31.2 percent of Kestrel.
Can we get a sample based on our own application?
Yes. Talk to us about reviewing a small batch of your real applications, so you can judge the packets on cases you know.
Does a clean sanctions screen mean the applicant is cleared?
No. A screen records that the named lists, as read at a stated time, had no match for the names screened. It is an observation, and your decision uses it alongside everything else in the packet.
Sources
- 31 CFR 1010.230, Beneficial ownership requirements for legal entity customers (eCFR), accessed 2026-09-30
- Sweat AI Check agent contract (/ai): evidence packet, assessment and screening rules, accessed 2026-09-30