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VAAS · Know Your Partner

Your partner's risk is your regulatory risk.

Validate the partner, shareholders, and ultimate beneficial owner (UBO) in a single call, with an anti-corruption matrix and continuous monitoring across the channel lifecycle.

The problem

The channel operates in your name. And the regulator knows it.

Three pain points that travel together in channel programs, BaaS, marketplaces, and third-party distribution.

Opaque chain

You cannot see the owner behind the owner.

The partner is a legal entity. Behind it are shareholders, and behind them are holding companies and individuals. Without resolving the chain down to the beneficial owner, you sign a contract without knowing who you are actually doing business with.

3+
common ownership chain levels before reaching the real UBO
Strict liability

The partner's act falls on you.

Law 12.846 and the FCPA hold the company liable for corruption committed by third parties on its behalf, regardless of intent. An integrity program requires documented partner due diligence, or the defense does not exist.

Strict
anti-corruption liability does not require that you acted with intent
Growth without control

The channel program grows faster than the diligence.

Hundreds of partners onboard each month. Manual analysis cannot keep up, so most enter without a check, or with a check that goes stale the next day. The channel becomes the compliance blind spot.

1x
manual diligence happens only at entry, never again
What we cross-check

Everything in a single call.

Public and private sources queried in parallel, normalized and weighted by the use-case matrix.

Ownership structureUBOPolitical exposureSanctionsCivil and criminal proceedingsCommercial integrityDigital reputation
Regulations covered
FCPAUK Bribery ActLei 12.846BACEN 4.943
Anatomy of a Dossier

From legal entity to UBO. One page.

Not a loose CNPJ lookup. The ownership chain resolved, crossed with anti-corruption lists, and returned as a ready-to-review report.

DOSSIER · KYP-2024-04212 · 03/Mar 14:22
Canal Sul Distribuidora Ltda · 28.904.***/0001-55
Send to desk
Ownership structure
Legal entity · ReceitaActive · regular
Direct shareholders4 individuals validated
Chain · levels3 (1 holding)
UBO identifiedIndividual · 38%
Checks (38 run)
FCPA · screening
UK Bribery Act
OFAC / UN Sanctions
!PEP · UBO (municipal)
Commercial standing
CNJ · shareholders
!Adverse media · UBO
Digital reputation
Score · anti-corruption matrix
Political exposure (PEP)Medium · 64/100
Reputational riskMedium · 71/100
Commercial integrityLow · 92/100
Global score74/100 · yellow zone
AI-generated summary

Recommendation: Send to desk. UBO with political exposure (elected municipal office 2020-2024) and 3 adverse media mentions of medium severity. FCPA and sanctions clear, but the anti-corruption matrix requires a human decision and an audit clause in the channel contract.

1
Ownership chain resolved down to the UBO

The engine walks shareholder by shareholder, crosses holdings, and identifies the individual who actually controls the partner. Each level points to the source.

2
Anti-corruption matrix, not a generic score

FCPA, UK Bribery Act, and Law 12.846 applied to the real data of the partner and each UBO, weighted by your channel policy.

3
Report with auditable trail

The agent reads the full dossier and drafts the recommendation. Who decided, when, and on what basis is logged - the proof of diligence the law requires.

Regulatory

What the law already requires from you.

Not a future project. Four instruments in force turn a poorly validated partner into a direct risk for your company.

FCPA
US · extraterritorial

Foreign Corrupt Practices Act

Holds the company liable for bribery committed by third parties and partners. Reaches operations with any US nexus. Documented partner due diligence is the heart of the program.

UK BA
United Kingdom · 2010

UK Bribery Act - failure to prevent

Creates the offense of "failure to prevent bribery". The only defense is proving adequate diligence procedures over those operating on your behalf.

12.846
Law · Anti-Corruption

Strict liability for third-party acts

The company is liable for corruption committed by a partner on its behalf, regardless of intent. An integrity program requires third-party due diligence, a mitigating factor in sentencing.

4.943
CMN · Resolution

Risk management for partners and correspondents

Institutions are liable for the conduct of correspondents and business partners. Requires continuous risk assessment and monitoring of the channel.

Rollout

From kickoff to go-live in 4 weeks.

The architecture is multi-tenant. What changes are the anti-corruption matrix, desk approval thresholds, and your channel program integrations.

01
Week 1

Discovery & scope

Map partner types, starting anti-corruption matrix, and integrations with the channel system.

02
Week 2

Matrix configuration

Tune weights, red flags, and approval thresholds. First sample reports for compliance team validation.

03
Week 3

Directed pilot

Resolve chain and UBO for a slice of the partner base. New onboardings already run through the VAAS flow.

04
Week 4

Channel go-live

Full base under continuous monitoring. Ownership change and adverse media alerts active. Team trained.

Ready?

Decide in seconds.
Start with a meeting.

In 15 minutes we show how VAAS works in your scenario, with your rules, your data, your volume.

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