Compliance module · KYB · KYC · AML/ATF

Onboarding diligence that never fakes a pass.

Screen a client, adjudicate what comes back, sign a verdict, and hand a regulator a hash-chained evidence bundle. The AI reads the documents. The analyst decides.

Start a compliance screeningSee module pricing

An add-on module on any paid tier · one expert module included at Enterprise

How it runsThe eight stepsThe AI layerThe catalogRisk & decisionsEvidenceMonitoringPricing
app.papervault.ca/compliance/okonkwo-holdings
A screening result: candidate hits, adjudication, and the signed verdict
30of 46
Checks returning a machine result today. The rest route to an analyst with an honest finding.
9

Check groups you switch on and off per service line

7

Live source adapters behind the AML, registry and media checks

0

Checks that report a pass they cannot evidence

A cleared file is only worth what you can prove about it later.

The vendor PDF nobody can re-open. The shareholder who held 40 percent through two holding companies. The clean result you cannot show the workings for, after the analyst who signed it has left.

Paper Vault records the question it asked, the answer it got, and the hash that proves neither changed.

The engagement

Compliance review

One client, one file, one decision — sitting beside every other case your firm runs, not in a separate tool.

The programme

Screening template

Which checks run, who owns each, and what your policy says when a source cannot answer. Draft, publish, version.

The execution

Screening

One run, snapshotting the programme as it starts. Revising the template later changes nothing you already signed.

How a review runs

One button starts it. Your client never learns the word “screening”.

01

Launch

One wizard opens the case, grants portal access, and emails an invite.

02

The client collects

A checklist and a form in the portal. No account to configure.

03

The gate holds

Screening stays locked until the files are in. Sequencing, not a reminder.

04

The run

One AI pass reads every document; the AML checks dispatch live.

05

Adjudicate and sign

A position on every check, then one verdict and one signature.

06

Monitoring

Re-screens on cadence and opens a task when something changes.

Lookup is evidence, not a guess

An ambiguous email shows you the candidates and asks. A shared domain never attaches a partner on its own.

One link, three password modes

Set, skip, or verify — resolved when the link is opened, so the sender never needs to know which applies.

Two windows, kept separate

How long a link opens the case, and how long it skips the password, are different settings. Shared mailboxes make that matter.

app.papervault.ca/portal/home
What the client sees: a checklist and a form, never the screening behind it

Eight steps, and two of them come before any query goes out

Before you ask an outside source about a client, you read what the client sent. That is why the first two steps exist.

01

Data review

Open

The intake exactly as submitted, annotated with what the AI validation flagged.

02

Documents review

Open

Approve or reject each file. A rejection re-opens that item in the client’s portal.

03

Client

One entity required

Subject entities, AI-extracted or added by hand, and the ownership tree.

04

Template

Read-only

The checks this screening runs, with owners and blocking flags.

05

Screening

Locked until documents and intake are in

The run, with a live progress overlay. Sources snapshot as it starts.

06

Review and report

Where the AI suggestions surface

A position on every check, a ruling on every hit, and the scoring report.

07

Additional information

Optional — locks the verdict, except decline

AI builds a form for what would clear each finding, sends it, and re-runs on approval.

08

Verdict

Locked while any check is unconfirmed

One decision, one rationale, one signature. The report generates and attaches.

Every Continue says why it is locked — “three still unconfirmed, sign-off stays locked” — rather than showing a dead button.

The AI layer

Seven AI surfaces. Not one of them decides anything.

Extraction is the AI’s job. Adjudication is not.

Vision reads the machine-readable zone; code computes the checksum. Where verification is deterministic, a check passes on its own. Where it is a judgement about authenticity, the AI produces a triage signal that routes to an analyst — never a clear.

Entity extraction

Proposes structured subject entities from the submitted forms.

Never persists — the reviewer accepts.

Ownership extraction

Proposes an ownership tree from the KYB forms and corporate documents.

A proposal. The analyst curates.

Document field extraction

One pass over every document — names, identifiers, dates, the machine-readable zone, bill figures — that five checks then read.

Extraction only. The checks are arithmetic.

Executive summary

Drafts the report narrative, and degrades to empty rather than inventing one.

Media triage

Relevance per article, so a common name is not forty findings.

Remediation form design

Turns unresolved findings into the exact questions and uploads that clear them.

Review agent

Reasons over the whole case file and proposes a result per check, with citations.

Advisory columns only. It cannot touch the verdict.

Every call is metered against a per-screening ceiling and logged with what it cost.

Your documents never train anyone’s model.

The review agent

Advisory only

It reads the whole case file, searches your knowledge base, and proposes a result per check with citations. Three rules bound it:

Advisory columns only. It never sets a result, a decision, or the verdict.
Knowledge arrives as labelled tool results, never pasted into the prompt — so the grounding is auditable.
Every call rides the evidence chain. What it read stays inspectable.

Your own knowledge base

AML policy, typologies, jurisdiction rules and your own written procedures, retrieved and cited. Each check also carries a rubric, so the model is never asked to invent your risk appetite.

Retrieval is scoped to your tenant. One firm’s knowledge never informs another’s.

URL ingestion is guarded: HTTPS only, IP literals refused, size and time caps, and a managed domain allowlist.

46 checks in nine groups. You choose which ones run.

Declare the service, the subject and the diligence level, and the programme pre-selects itself. Every selection stays yours to change.

Global AML screeningBlocking
Sanctions, PEP, media, debarment, crime, export control
10
IdentityBlocking
Name, date of birth, address and identifier
6
Document forensicsBlocking
Checksums, zone against printed page, file metadata
6
Ownership and control
The chain unwound, multiplied out and aggregated
6
Biometrics and liveness
Face match, liveness, injection and deepfake detection
5
Business legitimacy
Registry, standing, substance, certificates, constitution
5
Proof of address
An in-window bill, with the arithmetic on it checked
4
Financial risk profile
Source of funds, and the stated business model
2
Ongoing monitoring
The perpetual re-screen and its baseline
2
Checks per group. A blocking group holds sign-off until it is confirmed — a default you set, not a rule imposed on you.

First match wins — and the last branch is an honest refusal

Branch 01

A specialised resolver

Deterministic code over extracted facts: checksums, date windows, bill totals, registry reconciliation. These can pass on their own.

Branch 02

A live source

The AML and registry checks dispatch to their adapters and classify each hit by the topics it carries.

Branch 03

Nothing can answer it

It returns for review, says why in plain words, and — if blocking — correctly holds your sign-off.

Pass

Verified by something deterministic, and the finding says what.

Flag

A real adverse signal, with the candidate records attached.

Review

An honest “this needs a person”, never a pass by omission.

That is the machine signal. Your analyst’s own position is a separate record and always theirs.

Anti-money-laundering & anti-terrorist-financing

All ten AML checks, all wired

Hits are classified by the topics an entity carries, not by which list they came from — so a sanctioned politically exposed person flags sanctions and PEP. One lookup, not ten.

Sanctions
Consolidated programmes, matched on the entity
PEP
Politically exposed persons, by role
Relatives and associates
Review, never an auto-flag
Adverse media
Web search, GDELT and US federal court records
Debarment and exclusion
World Bank, SAM, HHS/OIG, development banks
Law enforcement
Wanted notices and criminal records
Regulatory enforcement
Regulator warnings and actions
Offshore leaks
The ICIJ corpus and persons of interest
Export control
Export-control and export-risk designations
OFAC 50 percent
Aggregated indirect ownership, where a tree exists
Ownership & control

Who really owns this, once you multiply it out

The AI proposes the tree; your analyst curates it. Six checks then read it — proportional multiplication, the 50 percent aggregation, control persons, and the fallback when no natural person resolves.

A layer recorded at zero percent that still has owners beneath it is surfaced as a gap in the disclosure, not dressed up as a result.

With no curated tree, all six fall through honestly. The tree locks at sign-off and joins the legal record.

Subject Co.Holdco A60% directHoldco B25% directDirector15% directNatural person36% indirect · beneficial ownerNominee layer0% recorded · owners beneath60% × 60% = 36% — over the threshold, so it surfaces as a beneficial owner in its own right.

Four mechanisms sit between the raw results and the decision.

Weighted risk scoring

Geography, customer, ownership, channel and screening outcomes — your weights, your bands. Stamped so a signed report stays reproducible.

Due-diligence tiering

Simplified, standard or enhanced. The upgrade is automatic and one-way; a downgrade needs its own permission and records who used it.

Consistency crosschecks

Name, identifier, date of birth, address and incorporation date reconciled across every source you hold. Each disagreement is ruled match, mismatch or explained.

Decision hard stops

Five conditions remove a clean approval, each with a suggested filing reason. Re-checked on the server when the verdict is emitted.

What a hard stop takes away

A confirmed true sanctions match
Aggregate indirect ownership over the threshold
A jurisdiction your policy prohibits
An industry outside your risk appetite
Beneficial ownership disclosure refused
No hard stopApproveApprove with conditionsEscalate to enhanced diligenceDecline
Hard stop in forceApproveApprove with conditionsEscalate to enhanced diligenceDecline

It removes only the clean approve. The analyst is never trapped — and disabling the button is a courtesy, not the enforcement.

Sign-off, separate from the verdict

Your template says which roles are required — analyst, MLRO, second approver. One live signature per role: a re-sign revokes the previous one and keeps both in the history.

The report

Twenty-four sections, in-app and as a Unicode-safe PDF. Copied onto the record at sign-off, so it says today what it said the day it was signed.

Every external query is recorded in an append-only hash chain.

The request that went out and the response that came back, each row carrying the hash of the one before it.

01Sanctions lookuphash 9f4c…a1
02Registry lookupprev 9f4c…a1
03Media searchprev 3b71…7e
04AI review groundingprev c5e0…04

The chain hash is read inside the same transaction that writes the row, so two screenings at once cannot interleave.

Verify

Recomputes every hash in order and surfaces the first inconsistent row — where and what changed, not merely that something did.

Export

The full log with verification metadata embedded, as one self-contained file a regulator can still open in five years.

Capture

Freezes the treasury and sanctions pages a hit cites as PDFs. Host-allowlisted: anything else is recorded blocked and never requested.

A completed run never changes
The programme snapshots as the run starts
The signed report is copied, not referenced
The ownership tree locks at sign-off
Retiring a check never rewrites history

Roughly sixty compliance actions are audited, every AI call among them. Evidence reads deliberately are not — high volume, no signal. Bulk export is, because extracting a compliance log is itself a compliance event.

app.papervault.ca/audit
The audit log: every compliance action, human and AI alike

A verdict is a moment. A programme is a subscription.

3 months6 months12 months24 months
01Re-runs the wired sources
02Diffs against the baseline
03Writes an event, notifies, opens a task
04Advances the baseline
Choose a cadence at sign-off, or enrol by hand. Event-driven subscriptions never auto-fire. Pause and resume any row.

The remediation loop

Mark what you cannot clear, and the AI builds a form asking for exactly what would clear it. The screening re-runs by itself on approval.

The verdict locks while a round is out — except decline. No firm should be forced to hold an application open for an answer it no longer needs.

Suspicious activity filings

Reason, regulator, narrative, status, and a snapshot of the triggers as they stood at filing. References are yours and citable — SAR-2026-0007.

Kept off the client surface by law, not by preference — the rule against tipping off. Two independent layers enforce it.

Thirteen separate permissions, from reading a screening to filing a report. Every entry point is tenant-only three times over — a portal-flagged permission, a defensive refusal, and row-level scoping. How security and tenancy work.

Priced on the depth of diligence, not on seats.

Attaches to any paid Paper Vault tier. Your whole team is included on all three.

Screening

Clear a name properly, with the evidence to show for it.

$249CAD / month
50 screenings a month · + HST
Get started
Includes:
Sanctions, PEP and relatives-and-associates screening
Adverse media with per-article AI triage
Debarment, law-enforcement, regulatory and export-control checks
Corporate registry and active-status cross-reference
AI document field extraction, with the page each field came from
The eight-step review wizard and typed sign-off
Hash-chained evidence log, verification and export
Structured report in-app and as a Unicode-safe PDF

Diligence

Most firms

Unwind the ownership, score the risk, get a cited second opinion.

$599CAD / month
200 screenings a month · + HST
Get started
Everything in Screening, plus:
Ownership and UBO unwinding, with the 50 percent aggregation
Weighted risk scoring on your own weights and bands
Due-diligence tiering — simplified, standard, enhanced
Consistency crosschecks across every source on the file
Decision hard stops, each with a suggested filing reason
The AI review agent — a cited second opinion on every check
AI-designed information rounds, with automatic re-run
Source-page capture — sanctions records frozen as PDFs

Programme

Run a whole AML programme — monitored, documented, grounded in your procedures.

Custom
Unlimited screenings · priced on your programme
Talk to sales
Everything in Diligence, plus:
Continuous monitoring on a 3, 6, 12 or 24-month cadence
SAR / STR register with citable references
Your own knowledge base — SOPs and jurisdiction rules the AI cites
Custom screening templates authored with you
Per-jurisdiction risk policy and industry appetite
Named compliance contact and a programme review
Data residency and a processing agreement for your MLRO

On Demand

Pay per review

Every Screening and Diligence feature, with nothing to commit to — for firms whose reviews arrive in bursts rather than every month.

No monthly charge and no minimum
Every Screening and Diligence feature, nothing held back
The same hash-chained evidence bundle and signed PDF
Move to a monthly plan whenever volume justifies it

Continuous monitoring, the SAR register and your own knowledge base stay with Programme.

$50CAD / review
No monthly charge · + HST
Get started

CAD, plus HST, on top of your Paper Vault subscription. One expert module is included at Enterprise. See the full rate card.

Run it on a real client file this week.

Launch one review, watch the client fill their own checklist, and read the report it produces.

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