MarketClair — MC-INV-1789414888561-IVLBVOZYM

1. Executive Summary

Final Decision & Risk Assessment

Final Decision

REVIEW

Established findings

2

Evidence

COMPLETE

2. Case Context & Triggered Rules

Risk Signals & Regulatory Basis

⚠ STRUCTURING · MEDIUM⚠ GEOGRAPHIC CONCENTRATION · MEDIUM

Applicable Regulatory Framework

France

Regulated entity responsible for this customer at decision time: TRADEFLOW-EU France SAS

Reconstructed after the fact: this decision was sealed before the applicable framework was frozen with each decision.

Procedures et controles internes LCB-FT

Code monetaire et financier, Legifrance.gouv.fr — Article L.561-32

Classification des risques LCB-FT

Code monetaire et financier, Legifrance.gouv.fr — Article L.561-4-1

Identification et vigilance a l'entree en relation

Code monetaire et financier, Legifrance.gouv.fr — Article L.561-5

Vigilance constante

Code monetaire et financier, Legifrance.gouv.fr — Article L.561-6

3. Decision Rationale & Evidence

Engine-Generated Narrative & Evidence Package

Outcome: REVIEW. At least one finding was established at MEDIUM severity. Contributing findings: Structuring (medium), Geographic Concentration (medium). This outcome routes the case to human review; it is not a determination of wrongdoing.

✓ Engine-generated narrative · v1.0.0 · Ruleset v1.0

Ref	Type	Description	Integrity
EVT-001	KYC Record	Customer verification at T0: verified	✓ VERIFIED
EVT-002	Transaction Data	Most recent transaction: 9,800 — FR → NL	✓ VERIFIED
EVT-003	Alert History	0 prior alert(s) on record	✓ VERIFIED
EVT-004	Sanctions / PEP	No sanctions or PEP exposure reported by the institution at T0	✓ RECORDED
EVT-005	Investigation Engine Output	2 finding(s) established — outcome REVIEW	✓ VERIFIED

Structuring — transactions behind the finding

Possible structuring: 5 transactions to beneficiary NEWCO-UNKNOWN-CONTACT within 14 days, each under the 10000 threshold. The 10,000 figure is the scenario's internal detection threshold, in the transaction currency; it is not a legal threshold.

#	Transaction
1	9800 to NEWCO-UNKNOWN-CONTACT on 2026-09-13
2	9400 to NEWCO-UNKNOWN-CONTACT on 2026-09-10
3	9600 to NEWCO-UNKNOWN-CONTACT on 2026-09-07
4	9750 to NEWCO-UNKNOWN-CONTACT on 2026-09-04
5	9900 to NEWCO-UNKNOWN-CONTACT on 2026-09-01

This finding reflects a transaction pattern within a fixed 14-day window, not proof of intent to evade reporting requirements. Some legitimate payment schedules or business practices can produce similar fragmentation; this signal should inform human review, not replace it.

4. Independent Verification & Cryptographic Proof

Decision Integrity — Independently Verifiable

This decision was sealed at the moment it was made. Any later alteration of the decision or of its data is detectable.

Integrity sealRecorded at decision time

Independent dateCertified by an independent timestamping authority: Tue, 06 Oct 2026 15:54:10 GMT

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Complete evidence file

Available to the institution's authorised users, and through a shareable verification link the institution can issue to a regulator, auditor or counsel.

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Public Verification API

POST request — no authentication required. Returns the verification verdict.

https://www.marketclair.com/api/aml-investigation/verify

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Reconstruction ID

Use this ID in any verification method above.

MC-INV-1789414888561-IVLBVOZYM

✓ Cryptographically sealed ✓ Immutable ✓ Independently timestamped ✓ Non-repudiable ✓ Independently verifiable ✓ Replay MATCH

This report is a signed summary. The complete evidence file — what was known at the decision date, the rules and obligations that applied, the decision and every later action on it — is available to the institution's authorised users.