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Financial services

A counterparty file a supervisor can still read years later.

Onboarding and counterparty files where every element of the decision can be shown to a supervisor with its source attached.

the worked caseTwo companies share a director, a former trading name and a registered agent. The record keeps them separate, links them, and says on what basis.

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A machined equal-arm balance with both pans empty and level, the fulcrum picked out in cobalt blue.

Two worked cases on this page, both fictional and both built the way a real one is: a value, the document it was read from, the date of reading, and the value it was chosen over.

The questions you get asked

Nobody asks for more information. They ask whether one line can be defended.

These are the questions that arrive after the work is delivered, from the party entitled to disagree with it. Every property on this page exists because one of them has to have an answer that does not depend on the person who assembled the file.

The four guarantees
  • 01

    Show me the file as it was when you approved the relationship, not as it is now.

  • 02

    On what basis did you decide these two entities are the same counterparty?

  • 03

    Which of these figures came from the client, and which from a vendor?

  • 04

    Where is the evidence for the check that returned nothing?

Asked by a supervisor on a thematic review, by internal audit, and by the credit committee that took the decision in the first place.

The buyer

Onboarding, KYC, credit and counterparty risk

Teams that must evidence not only what they concluded about a counterparty but what they knew at the moment they concluded it, to a supervisor reading the file years later.

What they fuse

Three kinds of source, one answer

Each kind arrives with different licence terms, different reader restrictions and different reasons to be wrong. The record keeps them distinguishable after the fusion, which is the part that is normally lost.

Internal onboarding and credit files

Client-supplied documents, relationship-manager notes and prior decisions held only in your systems.

Licensed screening and corporate data

Subscription registries, ownership graphs and adverse-media feeds whose licences bind who may read them and for how long you may retain them.

Public registers and filings

National company registers, beneficial-ownership disclosures, securities filings, sanctions and enforcement lists, and court records.

Worked case one

Two records that must not be merged

Two companies, one name, one exposure that must not be summed

Two entities in different jurisdictions carried the same trading name, a shared director and the same registered agent. A name is not an identity: folding one into the other would have misstated the exposure, and treating them as unrelated would have hidden it. The record holds two entities, relates them, and states the basis of the relation.

The figure beside this is what the reader sees: the value, its status, the source it was read from, and the value it was chosen over.

Two companies, one name, one exposure that must not be summedas of 4 February 2026
Legal entityTwo records, related, not mergedcitedTwo register extracts with distinct registration numbersA shared name and a shared director are candidate evidence, never decisive.
Ultimate beneficial ownerNamed individual, 42.5 per centcitedBeneficial-ownership filing, read 4 Feb 2026, page 3Chosen over a screening-vendor figure of 40 per cent carrying no filing reference.
Controlling shareholder of the second entityNot foundnot foundRegister carries no ownership field in that jurisdictionThe absence is recorded as an absence, not as no controlling shareholder.
A record as it stood on 4 February 2026. Values are fictional and written for demonstration.

Worked case two

The file as it stood on the day

The file replayed to nine in the morning on the day of approval

A supervisor reviewing an approval eighteen months later does not ask what the file says now. Between the two dates the screening list had been revised twice, the beneficial-ownership filing superseded, and the adverse-media item withdrawn by its publisher. Replay is not a reconstruction from memory or a rerun against current data: it returns the retained documents, their versions and the clearances that were in force that morning, which is a different answer from the one the same query gives today.

A different failure from the first case, on the same record and under the same four guarantees. Both are fictional; neither is a simplification of how the values are shown.

The file replayed to nine in the morning on the day of approvalreplayed to 11 September 2024
Screening result at approvalNo match, against the list of 10 Sep 2024citedRetained screening output, 11 Sep 2024, list version 2024-09-10The list has been revised twice since; today's result is a different value with a different date.
Beneficial ownership at approvalAs filed 2 Aug 2024citedBeneficial-ownership filing, retained copy, page 3, read 11 Sep 2024A superseding filing of 6 Mar 2025 sits on the record as a later value, not as a correction of this one.
Adverse-media item relied onBlockedblockedLicensed feed; the licence in force on 11 Sep 2024 permits no redistribution beyond the original reader groupThe item is named and dated in the file; its text is not reproduced for this reader.
Group exposure at approvalNot foundnot foundLimit system holds no retained position for 11 Sep 2024Recorded as not retained, rather than recomputed from today's positions and presented as what was known.
A file replayed to 11 September 2024. Values are fictional and written for demonstration.

Why the record has to hold

What the rules ask for, in their own words

These are the recordkeeping obligations that make a defensible value a requirement rather than a preference. We name them because our customers are measured against them; we make no claim to certify anyone against any of them.

Preservation of books and records

United States
17 CFR 240.17a-4 (SEC Rule 17a-4); FINRA Rule 4511

Required records must be preserved for prescribed periods in a form that either prevents alteration or retains a complete audit trail of every change, and must be produced promptly on request.

Record-keeping of orders and decisions

European Union
Directive 2014/65/EU (MiFID II) Art. 16(6)-(7); Commission Delegated Regulation (EU) 2017/565 Art. 72 to 76

Records must be sufficient for a competent authority to reconstruct each key stage of the processing of a transaction, and are retained for at least five years.

Risk data aggregation and reporting

Basel Committee on Banking Supervision
BCBS 239, Principles for effective risk data aggregation

A bank must be able to explain the lineage of the data behind a risk figure and reconcile that figure to its sources.

What changes for this reader

The same work, with the evidence attached at the moment it is read

Not a claim about speed and not a claim about savings: a description of the practice on each side. Everything on the left is what people in this role do today, and almost all of it is done well by people who resent having to do it that way.

How the product works
01today

An analyst reconciles a vendor ownership graph against a register extract by eye and writes only the conclusion into the file.

with the record

The file holds both, names the one relied on and the one it was chosen over, and states what separated them.

02today

A screening result that returned nothing is recorded as a tick in a checklist.

with the record

It is recorded as the list, its version, the query and the date, so a clean result is distinguishable from a check nobody ran.

03today

Two counterparties sharing a trading name are either merged into one exposure or treated as strangers.

with the record

They stay two records, linked, with the basis of the link stated, so the exposure is neither summed nor lost.

04today

Producing the file a supervisor asks for means reassembling it from archived mailboxes and whoever still works here.

with the record

The file replays to the date of the decision with the documents, versions and clearances that applied that day.

05today

A field the register does not publish is left blank, and a blank in a KYC file reads as absence of risk.

with the record

It is declared not found, naming the register and the date checked, so a gap cannot be read as a clean answer.

What you get

What the record guarantees financial services readers

The four guarantees, stated in the vocabulary of this sector. They are the same four everywhere; read them in general on the guarantees page, and see them applied to a live record on the demonstration.

  1. One record per legal entity, with former names kept and never deleted, and related entities linked rather than merged.
  2. Every element of a file carries the document it was read from, the page, and the date, including the elements you did not act on.
  3. A field a register does not publish is declared not found, with the register and the date it was checked, so the file never reads as a negative finding.
  4. The file as it stood on the day of the decision can be reproduced, with the licence and clearance state that applied that day.

Primary sources

The texts behind these obligations

The obligations on this page are drawn from the rule texts and supervisory principles listed below. They describe what regulators ask firms to keep and to be able to explain. We name them because readers in this sector are measured against them, and we do not certify anyone against any of them.

Reference pages that apply to this sector

Further reading in the articles

previous sectorPharmaceuticalsA pipeline page, a registry record and a February deck name three different lead programs. The record carries one, dated, and shows the two it was chosen over.next sectorGovernmentA supplier's registered address changed twice in eighteen months. The award file reproduces the address as it stood on the day of award, with the extract.