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Client onboarding / wealth management and private banking

Catch the paperwork problem before the custodian does.

Three decision engines check a new client’s file before anything leaves the firm: is the paperwork in good order, is the account transfer likely to go through, and is the source of wealth corroborated for the client’s risk rating. Every result cites the page behind it and is sealed in a signed receipt.

Three engines, one case per application Every value cited to its page Never a decision about the client
01 / what it checks

Three questions, asked before submission.

Each engine returns an outcome, the reasons for it and the page each reason rests on. A result that needs work says exactly what to fix or what to ask the client for.

EngineOutcomesWhat it looks at
Not in good order
paperwork
IN_GOOD_ORDER · NIGODocuments required for the account type, required fields that are missing or held, signatures, signature dates in the future or too old, expired ID, beneficiary percentages that do not add up to 100%, and owner details that differ between documents
Account transfer
ACAT
LIKELY_CLEAN · AT_RISKAccount title, TIN or registration type that does not match the delivering account, a stale statement, holdings that may not transfer in kind, a margin debit, fractional shares on a full transfer, a missing account number
Source of wealth
private banking
CLEAR · REVIEW · ESCALATEWhether independent documents corroborate the wealth the client declares, in proportion to the bank’s customer risk rating — with PEP, adverse-media and screening flags escalated wherever they appear
NIGO and AT_RISK are requests to fix paperwork, never a decision about the client. The paperwork rules are common causes of custodian rejects and ship as defaults — required documents, required fields and the signature and statement age limits are set per custodian.
02 / how a case is built

One application, every document, one case.

Gothink AIR reads the documents with the onboarding pack; the engines decide on what it publishes, never on raw text.

From a pile of paperwork to a checked caseOne application, three checks, one list of fixes
NINE DOCUMENTSAccount applicationGovernment IDForm W-9Certification of trustBeneficiary designationEntity resolutionACAT transfer formHeld-away statementAdvisory agreementGothink AIRREAD EVERY PAGECITE EVERY VALUEOne caseper applicationDetails that differ betweendocuments kept, both citedPaperworkNIGO CHECKIn good order→NIGO: fix list→Account transferACAT CHECKLikely clean→At risk: fix first→Source of wealthPRIVATE BANKINGClear→Review: ask once→Escalate→Every decision is sealed as a signed, replayable receipt — and lands in Gothink WitnessSubmit to custodianFix once, then submitStart the transferFix once, then transferOnboardAsk for named documentsTo compliance
Goes aheadA person fixes or reviewsEscalated An amber or red result is a request about paperwork, never a decision about the client.
1

Read

Application, government ID, W-9, certification of trust, beneficiary designation, entity resolution, transfer form, held-away statement and advisory agreement are read into governed records.

2

Join

Records are joined on the application into one case. Every value keeps its page; owner details that differ between documents are kept as conflicts, with both citations.

3

Decide

Each engine decides the case and the decision is sealed as a replayable, signed receipt — the same receipts Gothink Witness puts in front of an examiner.

4

Fix once

A NIGO or REVIEW lists exactly what is missing, so operations or the relationship manager goes back to the client once, not three times.

For your agents

On the MCP tool plane

The engines are exposed as tools alongside the rest of the decision layer. A KYC platform can hand over its verified records and get back a receipted decision, its reasons, the documents to request and the page citations.

For the reviewer

One printable review sheet

Each source-of-wealth decision has a one-page sheet: the result, what to ask the client for, evidence amounts with their pages, and the receipt. Personal values can be withheld when the sheet leaves the bank.

For your rules

Configuration, not code

Required documents, fields and age limits per custodian; risk tiers, currency rates and booking-centre settings per bank. Every threshold is a starting point for your compliance function to set.

03 / source of wealth

Corroborated in proportion to the risk, or sent to a person.

The source-of-wealth engine was rebuilt on review of its first version. What it will and will not count as evidence:

Three questions, in this orderA flag anywhere wins over everything else
The case+ RISK RATINGFlag in any document?PEP · adverse media · screeningYESEscalateto compliance, with theevidence gathered so farEnough evidence?independent documents, for the risk ratingNOReviewnames the documentsto ask the client forComplete and consistent?fields · dates · currencies · trustsNOReviewlists exactly what ismissing or conflictingNOYESYESClearcorroborated forthe risk ratingHOW THE SOURCE-OF-WEALTH ENGINE DECIDES
Goes aheadA person fixes or reviewsEscalated Every result, whichever way it goes, is sealed in a signed receipt with its page citations.
Evidence

Only independent documents corroborate

The client’s own assessment, their passport and the screening report never count as evidence of wealth. A sale agreement, grant of probate, tax filing, company accounts or trust deed can.

Risk

Proportionate to the rating

How many documents, whether they must state an amount, and how much of the claim they must cover all follow the bank’s customer risk rating. An unknown rating is treated as high risk.

Amounts

Currency aware, no rate assumed

Each document’s amount is tested against the claim. Where currencies differ, the rate comes from the bank — the engine never assumes one.

Escalation

A flag anywhere escalates

A PEP, adverse-media or flagged-screening value in any document escalates the case, even when another document says otherwise.

Structures

Trusts, companies and gifts

A trust needs a named settlor, a business source needs the company, a gift needs the letter and the transfer. The category “other” always goes to a reviewer.

Freshness

Statements go stale; probate does not

Statement age limits are set per document type, historical evidence stays valid, and future-dated documents are caught.

How much evidence each risk rating needsThe engine’s defaults — your risk function sets the real ones
Independent documentsMust state an amountAmount must cover the claimApproved public sourcesLow risk1 documentNot requiredn/aCountMedium risk1 documentRequired75%CountHigh riskalso an unknown rating2 documentsRequired100%Do not count
The client’s own assessment, passport and screening report never count as evidence. Amounts in another currency are compared only at a rate the bank provides.
Booking-centre settingsWhat we ship
Singapore and Hong KongA draft settings file for the bank’s compliance function to sign off, with its basis stated (MAS Circular AMLD 05/2026, MAS Notice 626, the HKMA AML/CFT Guideline) and the open decisions listed. It is not advice and is not in force until your compliance function approves every value.
Other centresBuilt with a design-partner bank from its own policy.
Live demo / in the Decisions console

Change the case, watch the decision change.

Five invented private-banking cases — a company sale, a self-declared claim, an inheritance part-covered in two currencies, a trust with no named settlor, and a politically exposed person. Change the risk rating, the amount, the PEP flag, the documents on file or the booking-centre settings, and each change is decided live, sealed in a signed receipt, with its review sheet and a one-click check of the receipt chain. The cases are fictional: the demo shows how the engine behaves, not how accurate it is.

04 / measure it

The one number a bank should ask for, measured on its own files.

How often the engine agrees with your reviewers on real files, and whether it ever clears a file they would not. A gold set someone writes by hand tests software; it measures nothing, and the scorer refuses to call it a measurement.

1

Agree the criteria first

GO criteria are agreed in writing before any pack is scored. The proposed default is strict: no false CLEAR and no missed escalation.

2

25 to 50 real packs

Anonymised by the bank before they leave it, mixing the risk ratings and categories the booking centre actually sees — trusts and company sales included.

3

Reviewers decide blind

Your KYC reviewers decide each pack without seeing the engine’s result. Nothing leaves your machine.

4

Every disagreement discussed

False CLEAR, missed escalations, straight-through, over-review, review minutes and reason codes — then a fresh set of packs, never the same one again.

What a small pilot can and cannot prove. With 25 to 50 packs, zero observed false CLEARs still allows a true rate of up to about 13% (25 packs) to 7% (50 packs) at 95% confidence — the report prints that interval next to the count. A field-level step also measures how well the key values (amounts, currencies, dates, risk rating, PEP status) are read off the page.
05 / status

What is built, and what is not.

PieceStatus
NIGO and ACAT engines, onboarding packBuilt — pack wealth_onboarding v1.0.0, nine document types
Source-of-wealth engine and packBuilt — engine and pack source_of_wealth v1.1.0, seventeen document types
Live demo in the Decisions consoleOn the cloud service — fictional cases only
Pilot kitBuilt — decision agreement and field-level accuracy
Accuracy figureNot claimed — none will be published until a pilot measures one
Console screen for onboarding operationsNot built yet
Custodian-specific rule setsNot built yet — they come from each custodian’s requirements and reject codes
Client onboarding / design partners wanted

Run the pilot on your own files.

We are looking for wealth managers and private banks to measure the engines against their own reviewers, and to shape the custodian rules and the operations screen with us.