Legal and beneficial ownership is combined until it is separated.
The Standard CDD Corporate Checklist focuses on the core elements required when onboarding corporate clients, including:
Entity identification and verification
Ownership and control
Directors and controllers
Source of funds and source of wealth
Purpose of the relationship and expected activity
Sanctions, PEP, and adverse media screening
Risk assessment, approval, and post‑onboarding monitoring
Another fine. Another firm caught out by the Money Laundering Regs 2017
The Standard CDD Corporate Checklist focuses on the core elements required when onboarding corporate clients, including:
Entity identification and verification
Ownership and control
Directors and controllers
Source of funds and source of wealth
Purpose of the relationship and expected activity
Sanctions, PEP, and adverse media screening
Risk assessment, approval, and post‑onboarding monitoring
The CDD Toolkit: From Analysis to Action
The Standard CDD Corporate Checklist focuses on the core elements required when onboarding corporate clients, including:
Entity identification and verification
Ownership and control
Directors and controllers
Source of funds and source of wealth
Purpose of the relationship and expected activity
Sanctions, PEP, and adverse media screening
Risk assessment, approval, and post‑onboarding monitoring
Law Firm Compliance Toolkit
The Standard CDD Corporate Checklist focuses on the core elements required when onboarding corporate clients, including:
Entity identification and verification
Ownership and control
Directors and controllers
Source of funds and source of wealth
Purpose of the relationship and expected activity
Sanctions, PEP, and adverse media screening
Risk assessment, approval, and post‑onboarding monitoring
The US waiver isn’t the real story. The regulatory gaps are.
The Reality of "Identity Laundering"
Vessels in the shadow fleet don't just appear on a list; they carry a trail of management shifts and flag changes designed to evade detection. To truly mitigate risk, firms must screen for the ISM Manager’s HQ and historical ownership, not just the ship’s current name.
The Solution: Audit-Ready Data
To help firms automate this process, I have released the raw investigative dataset for all 496 vessels designated in the late 2025 sweep. Developed using our proprietary three-stage identity-laundering model, this dataset features:
One unique record per IMO number (de-duplicated).
Full Entity Mapping: ISM Managers, Registered Owners, and Commercial Owners.
Jurisdictional Risk: Country of Incorporation for all managers and owners.
Beyond the List: Mapping the 496 Vessels of Russia’s Shadow Fleet
The Reality of "Identity Laundering"
Vessels in the shadow fleet don't just appear on a list; they carry a trail of management shifts and flag changes designed to evade detection. To truly mitigate risk, firms must screen for the ISM Manager’s HQ and historical ownership, not just the ship’s current name.
The Solution: Audit-Ready Data
To help firms automate this process, I have released the raw investigative dataset for all 496 vessels designated in the late 2025 sweep. Developed using our proprietary three-stage identity-laundering model, this dataset features:
One unique record per IMO number (de-duplicated).
Full Entity Mapping: ISM Managers, Registered Owners, and Commercial Owners.
Jurisdictional Risk: Country of Incorporation for all managers and owners.
A Practical Guide to High‑Risk Corporate Onboarding: CDD Essentials Every Firm Should Know
CDD for High‑Risk Corporate Clients: Why Firms Keep Getting It Wrong — and What Good Looks Like
High‑risk corporate onboarding remains one of the most challenging areas in financial crime compliance. Despite years of regulatory guidance, enforcement action, and internal training, many firms still struggle to apply a consistent, risk‑based approach when dealing with complex entities, opaque ownership structures, and cross‑border activity.
The problem isn’t usually a lack of policy. It’s the gap between what the policy says and how people apply it in real cases.
To help bridge that gap, I’ve created a free downloadable guide that breaks down the core principles of CDD and the practical realities of onboarding high‑risk corporate clients. It’s built from real‑world experience and designed to give teams clarity, structure, and confidence.
Free Standard CDD Checklists: A Practical Guide for Corporate and Individual Client Onboarding
The Standard CDD Corporate Checklist focuses on the core elements required when onboarding corporate clients, including:
Entity identification and verification
Ownership and control
Directors and controllers
Source of funds and source of wealth
Purpose of the relationship and expected activity
Sanctions, PEP, and adverse media screening
Risk assessment, approval, and post‑onboarding monitoring
When your compliance controls look fine on paper but fail in practice
Most firms only realise their controls don’t work when something triggers scrutiny, an audit finding, a backlog, regulator questions.
Policies exist, training exists but operations don’t line up with risk.
Clear workflows, defined escalation, behavioural thresholds, MI that shows control.
New Intelligence Release: Russia’s Shadow Fleet
After months of forensic work, we've published a dataset mapping 496 vessels linked to Russia’s post‑2022 sanction evasion network, anchored entirely to UK sanctions law, not speculation or recycled lists.
It’s built around UK sanctions relevant identifiers and provides a clean, consolidated way to pull:
- Previous vessel names
- Historical managers and owners
- Flag changes
- Key identifiers
