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FATF Recommendations risk-based CDD and ongoing monitoring / FATF Recommendation 24 beneficial ownership of legal persons / Kenya beneficial ownership and digital credit provider controls / OECD responsible business conduct due diligence / World Bank integrity compliance and IFC due diligence
| Counterparty | Role | Surface | Exposure | Readiness | Status |
|---|---|---|---|---|---|
Nairobi Fresh Supplies Ltd MER-KE-5501 |
| merchant |
| rfq |
| KES 3.8M |
Registration BO current Screening clear |
| within 8decb5467a37 |
Mombasa Agro Inputs Co SUP-KE-9210 | supplier | scf invoice | KES 6.3M | Registration BO current Screening clear | within dc803de01473 |
Lake Region Millers PLC ANC-KE-4420 | anchor buyer | group procurement | KES 12.4M | Registration BO current Screening clear | within d9980d370681 |
Kilindini Motors Importers Ltd DLR-KE-3188 | dealer importer | vehicle import | KES 8.9M | Registration BO current Screening clear | within 3f2e2e8085f8 |
Rift Last Mile Logistics LOG-KE-7004 | logistics partner | rfq | KES 1.2M | Registration BO current Screening clear | within ba84f7c9f7dc |
Eldoret Hardware Collective MER-KE-8842 | merchant | rbf line | KES 4.5M | Registration BO current Screening clear | within d8524a2c8dae |
| Relationship | Limit | Gate | Status |
|---|---|---|---|
MER-KE-5501 rfq | KES 4.0M | Exposure clear Evidence ready Abuse clear | within e7ab48a6e02d |
SUP-KE-9210 scf invoice | KES 7.0M | Exposure clear Evidence ready Abuse clear | within d41efe4aba11 |
ANC-KE-4420 group procurement | KES 15.0M | Exposure clear Evidence ready Abuse clear | within cd2b7e5c5cc8 |
DLR-KE-3188 vehicle import | KES 10.0M | Exposure clear Evidence ready Abuse clear | within 8b275af1c7a0 |
MER-KE-8842 rbf line | KES 5.0M | Exposure clear Evidence ready Abuse clear | within c1b7de200e6f |
| Control | Metric | Current | Management action | Status |
|---|---|---|---|---|
Business registration, tax PIN, privacy notice, and legal-name verification 223092d3221e | registration and tax verification ratio | 100% | Hold onboarding and marketplace actions until registration, tax, and privacy evidence is complete. | within |
Beneficial ownership verification and current ownership-register evidence fa1242f2d83a | beneficial ownership ready ratio | 100% | Block approvals, exposure increases, and renewals where beneficial ownership is absent or stale. | within |
Sanctions, PEP, adverse media, and prohibited-party screening 431ccceb69d9 | screening ready ratio | 100% | Suspend onboarding and route hits to financial crime compliance. | within |
Bank account, permit, license, and settlement readiness verification 5d8faeed69a5 | bank and permit ready ratio | 100% | Hold settlement, award, and drawdown actions when bank or permit evidence is incomplete. | within |
Expected activity profile and velocity monitoring 723070907aa2 | expected activity monitoring ratio | 100% | Route unexplained velocity changes to fraud and financial crime triage before exposure increases. | within |
Marketplace abuse, duplicate invoice, bid manipulation, and fraud signal triage e8d48e4fe005 | marketplace abuse clear ratio | 100% | Hold award, invoice purchase, and financing when relationship abuse signals are unresolved. | within |
Relationship exposure, concentration, contract, source evidence, and invoice authenticity gates 58c9a3e0a7c1 | exposure gate ready ratio | 100% | Block exposure increases, awards, drawdowns, and settlement when gates fail. | within |
Risk-tiered KYB renewal and relationship review cadence db30546ac019 | renewal ready ratio | 100% | Suspend new exposure for overdue high-risk reviews and downgrade stale counterparties to pending review. | within |
Enterprise manifest coverage for KYB controls bcbd7a0deebf | risk control manifest coverage ratio | 100% | Open manifest remediation for any missing control mapping or evidence custody route. | within |
KYB evidence custody, package hashing, and board-ready action queue 9e11b44ed400 | evidence custody ratio | 100% | Regenerate custody package and hold board sign-off when hashes or action-pack routes are incomplete. | within |
| Action pack | Evidence | Owner | Deadline | Status |
|---|---|---|---|---|
| No business network KYB governance action packs are required for the current evidence set. | ||||