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ADR-0073 — Round-2 entity-resolution & signal hardening (name-collision guard, vertical/licence consistency, financials-ingestion gap, payment-account-outside-licence)

  • Status: Accepted
  • Date: 2026-06-27
  • Context source: Officer primary-source recertification of OB Holding 1 OÜ (round 2), docs/research/2026-06-26-ob-holding-ai-interpretation-verification.md §Round 2; findings register R9–R12 (docs/research/2026-06-26-regression-audit-findings.md).
  • Relates to: ADR-0024 (entity matching), ADR-0049 (registration-number identity mismatch), ADR-0067 (fail-closed outputs), ADR-0020 (EBA weighted-max), ADR-0045 (sanctions suppression), ADR-0033 (document gap analysis).

Context​

A second, primary-source-verified review of the OB Holding 1 OÜ dossier escalated the verdict to CRITICAL / REJECT and exposed four new automated-dossier defect classes. The most serious is a confident-wrong entity attribution: the dossier named "Fairfax Financial Holdings Limited" — an unrelated multi-billion-dollar Canadian insurer — as the ultimate parent, purely on a name match. In an MLRO's hands a wrong UBO/parent is worse than an absent one: it manufactures false certainty in the ownership chain they personally certify. Three further classes: a vertical mislabel (gambling operator labelled "Payment Service Provider"), financials present-but-not-ingested read as benign "insufficient", and a missing signal for funds received into a payment account outside the entity's licence jurisdiction (€31.6m into a Lithuanian Paysera account under an Estonia-only gambling licence).

Decision​

  1. Name-collision guard (R9). No parent / UBO / related-entity attribution may be resolved on name similarity alone. Resolution requires a corroborating identifier — registration number, jurisdiction match, or LEI. A name-only candidate is surfaced as an unverified candidate (clearly labelled, never folded into the resolved chain or the report's "ultimate parent"). This extends ADR-0024/0049 from "don't merge across jurisdictions on reg-number" to "don't attribute on name without an identifier" — fail-closed: absent corroboration, do not assert identity.
  2. Vertical/licence consistency check (R10). When a stated vertical / MCC conflicts with the licence evidence or registry activity (e.g. MCC 7995 gambling licences present but the profile says PSP/PSD2), emit a discrepancy finding rather than silently carrying the wrong label. Taxonomy conflation is surfaced, not resolved by guess.
  3. Financials-ingestion gap (R11). When financial data exists upstream (registry / a source payload) but was not ingested, emit an explicit financials_ingestion_gap finding — never a benign "insufficient data" that reads as nothing-to-see (the ADR-0067 fail-closed rule applied to financials).
  4. Payment-account-outside-licence signal (R12). Add a deterministic red flag: a regulated entity receiving funds via a payment account in a jurisdiction outside its licence scope is HIGH (and CRITICAL where corroborated by enforcement/criminal context). A deterministic floor, not an LLM judgement.

Consequences​

  • Entity resolution becomes fail-closed on identity: it will sometimes show "unverified candidate parent" instead of a confident (possibly wrong) name. That is the intended trade — an MLRO must not inherit a fabricated chain. The candidate still surfaces for the officer to confirm against a primary source.
  • The four checks are additive scrutiny consistent with the mission rule (add scrutiny, never suppress a signal); none downgrades an existing signal.
  • The OB Holding round-2 position (CRITICAL/REJECT + R9–R12) is encoded into the test_no_false_reassurance.py ground-truth oracle, so a future regression that re-introduces a name-only parent, a PSP-for-gambling label, a benign "no financials", or that misses the payment-account signal, fails the suite.
  • Real-world detection of the underlying facts (the €31.6m, EPPO) remains coverage/search-limited (vendor-dependent) — these checks ensure that when the signals are present in the data, the system surfaces them honestly and never asserts a confident-wrong parent.