One map. Assembled once. Applied to everyone.
synthetic company · demonstration file · every figure computed, none real
Your obligations arrive from four directions and live in twenty signed PDFs. This is how they become one versioned object that every counterparty is measured against.
requirements-map 4.2.0 · 15 elements · dated 29.08 · every element traceable to a clauseStandard setters and industry practice
FATF R.10 · R.22 · R.24 · Wolfsberg CBDDQ 1.4 · Visa & Mastercard onboarding rules · EBA guidelines on ML/TF factorsThe regulator that licenses you
Bank of Lithuania, EMI licence 42 · AMLD5 as transposed · national AML/CTF law art. 9–14 · supervisory letter 03.2026Partner regulators and sanctions regimes
acquiring bank's regulator (DE) · sponsor bank policy annex 3 · UN Security Council consolidated · EU consolidated list · OFSI · OFAC SDNYour own signed policies
Risk & Compliance Policy v4 · Onboarding Standard v2.1 · Security & Privacy v3 · Operations & Governance v1.6 · High-risk Jurisdiction Annex v2
- Counterparty A3 of 15 closed · coverage insufficient · decision unavailable
- Counterparty B8 closed · 5 open · 2 documented outcome
- Counterparty C15 of 15 closed · ready to work with you
Onboarding opens when every element of the map is closed.
How the map is assembled.
Five steps, in order, and a person stands at the fourth. The assistant reads and proposes; it does not publish. Every element it proposes arrives with a pointer back into the page and clause it came from, and an element without one cannot be accepted.
- 01
Declare yourself
Licence, licensing regulator, partner regulators, sanctions regimes you answer to, the products you sell.
EMI · Bank of Lithuania4 partner regulators · 4 regimes - 02
Upload the signed policies
Ten to twenty documents, as signed. No template, no re-typing, no questionnaire about what they say.
14 documents · 402 pages2 superseded, set aside with a reason - 03
The assistant proposes elements
Each proposal carries the document, the page, the clause and the quote. It proposes; it never publishes.
19 proposed - 04
A person accepts, edits or rejects
Element by element, with the clause open beside it. A rejection is recorded with its reason, and stays in the record.
11 accepted · 4 edited · 4 rejectedby M. Ilves, MLRO - 05
The map is published as a version
Dated, numbered, immutable. Cases hold the version they were assessed under, forever.
requirements-map 4.2.0published 29.08 · active 29.08
The pointer is the product.
a requirements map with no provenance is a checklistclause
Publishing and activating are two different acts.
A published version is legible, diffable and quotable, and no case is measured by it yet. Activating one changes what new cases are assessed against — a separate control, a separate right, and a record of who used it. Cases already assessed keep the version they were assessed under.
Assembled from 14 signed documents. Accepted element by element by M. Ilves. This is the version every open case is measured against today.
Adds source of wealth above a turnover threshold, drops adverse media on directors in class 1 jurisdictions, and narrows the incumbency window. Legal review is not yet recorded.
| change | 4.2.0 | 4.3.0 |
|---|---|---|
| added | — | Source of wealth of the controlling party, where declared turnover exceeds EUR 1m. Onboarding Standard v2.1 p.7 cl. 3.2 |
| removed | Adverse media search on each director, all jurisdictions. Risk & Compliance v3 p.9 cl. 6.1 | Retained for class 2–4 only. Removed for class 1 by the March supervisory letter. reason recorded |
| reworded | Identity is verified against a government-issued document. | Identity is verified against a passport or national identity card. |
| reworded | Identify the beneficial owner holding 25% or more. | Identify the beneficial owner holding 25% or more, and evidence the identification. |
An element is in one of three states, and they are three different facts.
Closed by evidence
A fact from a source, with the date the source was current. Filled, and it lifts, because something is under it.
Open
Nobody has closed it yet, and waiting will help. A thin outline, no fill, flat — it is not a finding and it is not a failure.
Checked, and cannot be established
A source was asked and cannot answer. Dashed, hatched, recessed, and it never lifts — because nothing is under it, and that is the finding.
Element 07, in full.
- 1A natural person is named, with date of birth and nationality.
- 2The holding is evidenced end to end, each edge with its document or register and date.
- 3Identity is verified against a government-issued document.
| version | when | what changed | who · cases |
|---|---|---|---|
| 4.3.0 | 05.09 · published | "and evidence the identification" added. Condition 3 restated to name the document class. | M. Ilves · not active |
| 4.2.0 | 29.08 · active | Incumbency window narrowed from 180 to 90 days, following the March supervisory letter. | M. Ilves · 41 cases hold this |
| 4.1.0 | 07.07 · retired | Substitutes admitted for the first time, for four jurisdictions. Before this, the element could only be open or closed. | M. Ilves · 118 cases hold this |
| 4.0.0 | 27.03 · retired | Element introduced, from clause 8.3 of the policy signed that month. | M. Ilves · 64 cases hold this |
The map does not change. The filling does.
Two states of the same object: the map as published, and the map as one counterparty closed it. Eight elements closed on facts, five still open, two checked and recorded as documented outcomes. Same fifteen cells, same order, every time.
the registers,
the rules
Send us your policy pack. We will assemble the map in front of you.
Ten to twenty signed PDFs, as they are. You will see every proposed element with the clause it came from, and you will accept or reject each one yourself. You keep the map either way.