--- type: "nimble-use-case" name: "kyc-screening" description: "Nimble's KYC screening agent populates a case file on any business with its registration, officers and owners, sanctions and PEP checks, and adverse media by severity from the live web, with a low, medium or high risk rating. It reads national company registries and GLEIF, ownership records, sanctions lists, regulator and court sites and the press." use_when: "Preparing a KYC or KYB file on a business: registration, officers and owners, sanctions, PEPs and adverse media." not_for: "A sanctions or PEP screening of record, identity verification of individuals, legal advice." agent_id: "wsa_7cb184ce40994c75a598a23f24cccc84" price_per_agent_run: { low: 0.025, medium: 0.1, high: 0.5 } updated: "2026-11-11" --- # AI web research agent for KYC screening (Nimble) Nimble's KYC screening agent populates a case file on any business with its registration, officers and owners, sanctions and PEP checks, and adverse media by severity from the live web, with a low, medium or high risk rating. It reads national company registries and GLEIF, ownership records, sanctions lists, regulator and court sites and the press. - Human page: https://www.nimbleway.com/use-cases/finance/kyc-screening - Interactive demo: https://www.nimbleway.com/demos/kyc-screening - Agent context: https://www.nimbleway.com/use-cases/finance/kyc-screening/kyc-screening-agent.md - Skill for agents: https://docs.nimbleway.com/skills/kyc-screening/SKILL.md - Docs: https://docs.nimbleway.com/nimble-sdk/web-search-agents/overview ## 1. Choose this when - You are onboarding a customer, supplier or partner and want the public file before your formal checks. - You need the right legal entity: brands often map to several entities, and branches are not separate ones. - You want sanctions matches only when identifiers line up, and namesakes counted and left out. - You want adverse media triaged by severity, with regulator and court sources ranked above press. ## 2. Use something else when - You need a sanctions or PEP screening of record. Run names through your screening provider; use this to prepare the file. - You need to verify an individual’s identity documents. ## 3. Minimal request One run of the ready-made KYC screening agent (`wsa_7cb184ce40994c75a598a23f24cccc84`). ```bash AGENT_ID=wsa_7cb184ce40994c75a598a23f24cccc84 # Nimble's KYC screening agent curl -X POST "https://sdk.nimbleway.com/v2/agents/$AGENT_ID/runs" \ --header "Authorization: Bearer $NIMBLE_API_KEY" \ --header 'Content-Type: application/json' \ --data '{"input":"Run a KYC screen on Greensill Capital in the United Kingdom","effort":"high"}' # poll until is_active is false, then read the result curl "https://sdk.nimbleway.com/v2/agents/$AGENT_ID/runs/$RUN_ID" --header "Authorization: Bearer $NIMBLE_API_KEY" curl "https://sdk.nimbleway.com/v2/agents/$AGENT_ID/runs/$RUN_ID/result" --header "Authorization: Bearer $NIMBLE_API_KEY" ``` The screen is in `output.content`: `risk_rating` (low, medium or high) and `risk_rationale`; `registration` with `legal_name`, `registry_number`, `jurisdiction`, `status`, `incorporation_date`, `registered_address`, `lei` and `source_url`; `people` (officers and owners), `sanctions`, `pep`, `adverse_media` (with `severity`, `category`, `status`, `date`) and `related_entities`; `namesakes_excluded` counts dropped matches. ## 4. Use it from an agent Paste this into Claude, ChatGPT, Codex, Cursor or Grok: ```text Be my KYC research assistant using Nimble. Follow https://docs.nimbleway.com/skills/kyc-screening/SKILL.md. ``` The full skill is in section 7 below. - Frameworks: `@nimble-way/mastra`, `langchain-nimble`, `@nimble-way/ai-sdk`, `llama-index-tools-nimble`, `nimble_python`, `@nimble-way/nimble-js`. ## 5. Example runs ### Greensill Capital (recorded 2026-11-11) Input: Run a KYC screen on Greensill Capital in the United Kingdom Run record: high effort, 2.6 minutes, 8 pages cited. Risk rating: high Rationale: High risk: the entity is in administration (appointed 8 March 2021) with liabilities exceeding £1.6 billion; the Insolvency Service found conduct breaching directors' duties under the Companies Act 2006 and founder Lex Greensill agreed to a nine-year director disqualification (effective 23 June 2026 until June 2035) after transactions removed legal protections from a Credit Suisse fund's investment and $440 million was diverted, causing a $440 million loss to the fund; the LEI registration is lapsed. No sanctions or PEP hit on the entity itself. Registration: GREENSILL CAPITAL (UK) LIMITED · 08126173 · United Kingdom (England & Wales) · In Administration (joint administrators Chris Laverty, Russell Simpson and Will Stagg of Grant Thornton UK LLP appointed 8 March 2021; Russell Simpson replaced Trevor O'Sullivan as administrator pursuant to an order of the High Court dated 27 June 2022) · 2012-07-02 · 2138004D9J9DZUANAI93 (LEI registration LAPSED, last updated 2025-03-29) https://find-and-update.company-information.service.gov.uk/company/08126173 Sanctions: - Greensill Capital (UK) Limited: No match identified, No Greensill entity or officer found on the UK sanctions list in the sources reviewed; the entity appears in regulatory/insolvency records only PEP: - David Cameron: Former UK Prime Minister; serving as an adviser to Greensill at the time of the collapse (reported 5 March 2021) https://www.theguardian.com/business/2021/mar/05/credit-suisse-winds-down-10bn-in-funds-as-greensill-bank-prepares-for-insolvency Adverse media: - 2021-03-08 [high] Greensill Capital (UK) Limited collapsed into administration in March 2021 with liabilities of more than £1.6 billion (administration entered 8 March 2021) https://www.gov.uk/government/news/lex-greensill-to-be-disqualified-from-acting-as-a-company-director-in-the-uk-for-nine-years - 2026-06-04 [high] Lex Greensill agreed to a nine-year UK director disqualification after an Insolvency Service investigation: in late 2020 he caused the companies to enter transactions with Katerra that removed legal protections from the Credit Suisse (Lux) Supply Chain Finance Fund's investment, and caused or allowed Greensill Capital (UK) Limited to use $440 million received in November 2020 for purposes other than redeeming notes owed to the fund, causing a $440 million loss; conduct breached his Companies Act 2006 duty of reasonable care, skill and diligence https://www.gov.uk/government/news/lex-greensill-to-be-disqualified-from-acting-as-a-company-director-in-the-uk-for-nine-years - 2024-03-07 [high] The Insolvency Service commenced director disqualification proceedings against Alexander (Lex) Greensill, seeking disqualification of up to 15 years, in respect of his conduct as a director of Greensill Capital (UK) Limited and Greensill Limited (investigations began May 2022; a six-week trial was due to begin 8 June 2026 but ended via the disqualification undertaking) https://www.gov.uk/government/news/outcome-of-investigation-into-the-directors-of-the-collapsed-greensill-group - 2021-03-05 [high] Credit Suisse moved to wind down specialist funds worth $10bn (£7.2bn) mostly invested in loans linked to Greensill, after Greensill lost a NSW court battle to prevent an insurer withdrawing protection; Greensill was preparing to file for insolvency having lost the backing of Credit Suisse and GAM https://www.theguardian.com/business/2021/mar/05/credit-suisse-winds-down-10bn-in-funds-as-greensill-bank-prepares-for-insolvency Officers and owners: - Alexander David Greensill (Lex Greensill): Person with significant control (Active, notified 6 April 2016; nature of control: has significant influence or control over the trustees of a trust; DOB December 1976, British); also Director 2 July 2012 - 17 June 2026 (British) - Peter Edward Greensill: Director (2 July 2012 - 22 January 2018); DOB September 1981 (Australian) - Jason Richard Alexander Austin: Director (2 July 2012 - 21 June 2019) and Secretary (2 July 2012 - 16 September 2015); DOB March 1968 (British) - Patrick Joseph Allin: Director (8 February 2016 - 22 January 2018); DOB August 1951 (British) - David Campbell Brierwood: Director (1 January 2015 - 22 January 2018); DOB November 1960 (British) - William Crothers: Director (1 August 2016 - 4 February 2021); DOB November 1960 (British) - Alastair Kenneth Eadie: Director (19 February 2019 - 12 February 2021); DOB July 1966 (British) - Divya Sara Eapen: Director (13 July 2020 - 12 February 2021); DOB May 1980 (Singaporean) - Bradley Jay Gans: Director (15 December 2020 - 28 December 2020); DOB August 1960 (British) - Neil Albert Garrod: Director (24 July 2019 - 12 February 2021); DOB February 1964 (British) - William Roland Hartley-Urquhart: Director (20 May 2015 - 22 January 2018); DOB November 1958 (British) - Jonathan Edward Myott Lane: Director (14 December 2018 - 24 July 2019) and Secretary (16 September 2015 - 30 June 2020); DOB July 1971 (British, Irish) - Bartholomeus Gerardus Joannes Ras: Director (19 February 2019 - 12 February 2021); DOB March 1970 (Dutch) - Sean Denis Robson-Hanafin: Director (24 July 2019 - 20 December 2020); DOB January 1972 (British) - Maurice Nicholas Beech Thompson: Director (25 September 2014 - 22 January 2018); DOB April 1958 (British) - Christopher William Bates: Director (14 December 2018 - 9 January 2019); DOB January 1976 (British) - Rachel Justine Donnelly: Secretary (19 February 2019 - 11 December 2019) - Hayley Louise James: Secretary (30 June 2020 - 21 October 2021) - Chris Laverty: Joint administrator (Grant Thornton UK LLP, appointed 8 March 2021) - Russell Simpson: Joint administrator (Grant Thornton UK LLP; replaced Trevor O'Sullivan as administrator pursuant to a High Court order dated 27 June 2022) - Will Stagg: Joint administrator (Grant Thornton UK LLP, appointed 8 March 2021) ### Wirecard (recorded 2026-11-11) Input: Run a KYC screen on Wirecard AG in Germany Run record: high effort, 5.6 minutes, 20 pages cited. Risk rating: high Rationale: High risk. Wirecard AG, once a DAX-30 payments processor (HRB 169227, Amtsgericht München; LEI 529900A8LX4KL0YUTH71, now LAPSED), collapsed in June 2020 after EUR 1.9 billion supposedly held in Asian trust accounts was found not to exist, and filed for insolvency on 25 June 2020 with about EUR 3.2 billion of debt. Insolvency proceedings were opened on 25.08.2020 (Az. 1542 IN 1308/20) and the company was dissolved under § 263 AktG; the register entry continues ('aktiv') with no deletion as of 21.10.2026, so the legal entity subsists without trading. Confirmed adverse findings: KPMG's 2020 special audit could not verify the majority of 2016-2018 profits; the Munich I Regional Court declared the 2017 and 2018 annual accounts null and void (5 May 2022) and in September 2024 ordered former board members to pay EUR 140 million in damages, with a prior EUR 140 million default judgment against fugitive ex-COO Jan Marsalek; the BGH ruled on 13 November 2025 that shareholder damages claims are subordinated in the insolvency. Former CEO Markus Braun and two co-defendants remain on trial at Landgericht München I (opened 8 December 2022; 289th hearing day on 28 October 2026, no verdict yet, Braun in pre-trial custody since June 2020) — an open criminal proceeding. Former COO Jan Marsalek is a fugitive wanted under an Interpol red notice since August 2020, reported living in Moscow under a false identity with alleged Russian intelligence ties. Group entities drew regulatory actions (FCA freeze of Wirecard Card Solutions; MAS payment-services directions; BaFin criminal referral and resignations). No sanctions match was found (OFAC search empty; no EU/UK/UN listing in the sources reviewed) and no PEP was identified among the officers — Markus Braun's Austrian Chancellery advisory role is not a prominent public function and Marsalek is a criminal fugitive rather than a PEP. The combination of a dissolved, insolvent entity with confirmed fraud findings, ongoing criminal proceedings and fugitive executives drives the high rating. Registration: Wirecard AG · HRB 169227 (Amtsgericht München) · Germany (Bavaria) · Insolvent and dissolved: preliminary insolvency administration ordered by Amtsgericht München on 29.06.2020; insolvency proceedings opened by decision of 25.08.2020 (Az. 1542 IN 1308/20), dissolving the company under § 263 AktG (register entry of 03.09.2020). Insolvency administrator: Dr. Michael Jaffé, Munich. The register entry itself still shows the legal entity as continuing ('aktiv'); no final deletion as of the register data dated 21.10.2026 · 2007-08-06 (registration in the commercial register at Amtsgericht München; company traces to a 1999 founding and entered the stock exchange via reverse IPO of InfoGenie AG) · 529900A8LX4KL0YUTH71 (LEI registration status LAPSED; last GLEIF update 2020-11-13; entity status recorded as ACTIVE but non-conforming) https://online-handelsregister.de/handelsregisterauszug/by/Muenchen/HRB/169227/Wirecard-AG Sanctions: - Wirecard AG and its officers: OFAC SDN List and other OFAC sanctions lists (US); EU, UK and UN consolidated lists checked in the sources reviewed, No match identified: an OFAC Sanctions List Search for 'Wirecard' returned an empty results table (SDN list last updated 11/9/2026). No Wirecard AG entity or officer is named on the EU, UK OFSI or UN lists in the sources reviewed; the entity appears only in regulatory, insolvency and court records https://sanctionssearch.ofac.treas.gov/ PEP: - No PEP identified among Wirecard AG officers, directors or related parties: null https://en.wikipedia.org/wiki/Markus_Braun Adverse media: - 2020-06-25 [high] Wirecard AG filed for insolvency citing over-indebtedness after EUR 1.9 billion supposedly held in Asian trust accounts was found not to exist; it owed about EUR 3.2 billion in debt. The company had been a DAX member from September 2018 to August 2020 https://bbc.co.uk/news/business-53176003 - 2020-04-27 [high] KPMG's special investigation (published 28 April 2020) could not verify the business behind the majority of Wirecard's 2016-2018 profits: TPA transaction data, contracts, escrow account statements and bank confirmations were not made available, TPA partners did not cooperate, and the board never delivered a final management representation letter https://cdn.gmtresearch.com/public-ckfinder/hall-of-shame/Wirecard%20AG/KPMG_Special%20Investigation%20Report_Apr27-2020.pdf - 2020-08-25 [high] Insolvency proceedings opened by Amtsgericht München (Az. 1542 IN 1308/20); the company was dissolved under § 263 AktG with effect from the opening decision; the entire management board was axed and provisional insolvency administration had run from 29.06.2020 https://online-handelsregister.de/handelsregisterauszug/by/Muenchen/HRB/169227/Wirecard-AG - 2020-06-26 [high] UK FCA froze Wirecard Card Solutions Limited's business 26-30 June 2020 over safeguarding concerns; Singapore's MAS directed Wirecard's Singapore branch to stop payment services (September 2020); BaFin filed a criminal referral after Wirecard made misleading statements to investors during the KPMG special audit; BaFin president Felix Hufeld and deputy Elisabeth Roegele resigned over supervisory failures https://en.wikipedia.org/wiki/Wirecard - 2022-05-05 [high] The annual financial statements of Wirecard AG as at 31 December 2017 and 31 December 2018 and the profit-appropriation resolutions were declared null and void in full: the balance sheets were significantly overvalued, Wirecard made no profits in 2017/2018 but considerable losses, and dividends of about EUR 22 million (2017) and EUR 25 million (2018) were paid on the void accounts, mainly to major shareholders such as MB Beteiligungs GmbH, Dr. Markus Braun's holding company https://wirecard.com/?p=new_report&t=12 - 2024-09-05 [high] Former Wirecard management board members, including former CEO Markus Braun, were ordered to pay a total of EUR 140 million in damages plus interest to insolvency administrator Dr. Michael Jaffé for breaches of fiduciary duties; a partial default judgment had already ordered former COO Jan Marsalek to pay EUR 140 million; two former supervisory board members sued were found not liable for lack of causality https://globallitigationnews.bakermckenzie.com/2025/01/03/germany-wirecard-board-members-liable-for-eur-140-million - 2026-10-28 [medium] The criminal trial of former CEO Markus Braun and two co-defendants (Stephan von Erffa, former head of accounting, and Oliver Bellenhaus, former head of the Dubai subsidiary) at Landgericht München I opened 8 December 2022 on charges including commercial gang fraud, breach of trust, accounting/balance-sheet falsification for 2016-2018 and market manipulation; alleged bank loans of about EUR 1.7 billion and bonds of about EUR 1.4 billion, with 2026 reports putting the alleged loss at about EUR 3 billion; Braun denies the charges https://claimandresponse.com/subjects/wirecard-ag/wirecard-accounting-fraud/ - 2020-08-05 [high] Former COO Jan Marsalek fled Germany in June 2020 and remains a key suspect in the Wirecard scandal; a September 2025 investigation reported him living in Moscow under a false identity, and he is alleged to have used Wirecard to supply Wagner and other Russian military and influence groups in the Middle East https://themoscowtimes.com/2025/09/17/fugitive-wirecard-executive-living-in-moscow-under-false-identity-investigation-reveals-a90543 - 2023-06-01 [high] James Wardhana, Wirecard's international finance manager, was sentenced by Singapore's State Court in June 2023 to 21 months imprisonment, and Chai Ai Lim, Wirecard Asia's head of finance, to 10 months; Edo Kurniawan, head of accounting for Wirecard's Asia-Pacific operations, was accused of forged and backdated contracts to inflate profit https://en.wikipedia.org/wiki/Wirecard_scandal - 2025-11-13 [medium] In litigation arising from the Wirecard AG insolvency, the BGH held that shareholder damages claims based on misleading capital-markets disclosures are subordinated equity claims in the insolvency, overturning the Munich Higher Regional Court's decision that they ranked pari passu with other unsecured creditors — materially reducing dilution of ordinary creditor recoveries https://sullcrom.com/insights/memo/2025/November/German-Federal-Court-Justice-Decision-Wirecard-Insolvency Officers and owners: - Dr. Markus Braun: Chief Executive Officer / Vorstand, Aug 2007 – Jul 2020 (resigned 19 June 2020); largest single shareholder (>7%) (Austrian) - Jan Marsalek: Chief Operating Officer / Vorstand, May 2010 – Jul 2020 (dismissed/fled June 2020; fugitive) (Austrian) - Burkhard Ley: Vorstand (CFO), Aug 2007 – Mar 2018 - Rüdiger Trautmann: Vorstand, Aug 2007 – May 2010 - Alexander von Knoop: Vorstand (CFO), Mar 2018 – Jul 2020 (still shown as active board member on the register) - Susanne Steidl: Vorstand (Chief Processing Officer), Mar 2018 – Jul 2020 (still shown as active board member on the register) - James H. Freis Jr.: Vorstand appointed 01.07.2020 with sole authority to represent the company (interim CEO); stepped down 11 September 2020 - Stephan von Erffa: Prokurist (authorized signatory), Nov 2007 – Jul 2020; former head of accounting; co-defendant in the criminal trial - Oliver Bellenhaus: Former managing director of Wirecard's Dubai subsidiary; management board member; co-defendant who turned state's evidence - Thomas Eichelmann: Chairman of the supervisory board (at the time of the collapse) - Wulf Matthias: Former supervisory board member (chairman until 2020) - Tina Kleingarn: Former supervisory board member - Dr. Michael Jaffé: Insolvency administrator of Wirecard AG (appointed by Amtsgericht München) ### Garantex (recorded 2026-11-11) Input: Run a KYC screen on Garantex Europe OÜ in Estonia Run record: high effort, 4.2 minutes, 13 pages cited. Risk rating: high Rationale: High risk. (1) Sanctions: Garantex Europe OÜ (Estonian registry code 14850239) has been on the US OFAC SDN List since 5 April 2022 (CYBER4; RUSSIA-EO14024, with secondary-sanctions risk under Section 11 of E.O. 14024) and was re-designated under cyber authorities on 14 August 2025; it is also designated on the UK Sanctions List (RUS1421, asset freeze, trust services and director disqualification sanctions) since 4 May 2022, on the EU consolidated list since 24 February 2025 (Decision 2025/389, 16th sanctions package) and under Swiss SECO measures since March 2025. (2) Regulatory finding: the Estonian Financial Intelligence Unit found systemic AML deficiencies — over 90% of customers not identity-verified, failure to report suspicious transactions, funds moved through the company tied to crime — and the company surrendered its virtual-currency authorisation in February 2022 after processing over €5 billion in annual transactions. (3) Criminal charges: a US federal indictment unsealed 7 March 2025 charges its administrators with money-laundering conspiracy, IEEPA sanctions violations and operating an unlicensed money transmitting business; domains seized 6 March 2025 and over $26 million frozen. (4) Status: the Estonian legal entity was renamed Kihonzi Buzhaga OÜ and deleted from the commercial register on 20 March 2024, while the exchange operation continued via the successor exchange Grinex, itself designated by OFAC in August 2025. No PEP was identified among its people in the sources reviewed. Registration: Garantex Europe OÜ (renamed Kihonzi Buzhaga OÜ in the register before deletion; 'Invalid names: Garantex Europe OÜ') · 14850239 · Estonia · Deleted from the Estonian commercial register on 20 March 2024 (registered 18 November 2019); a deleted legal person has no persons with the right of representation and beneficial-owner history is not displayed · 2019-11-18 https://ariregister.rik.ee/eng/company/14850239 Sanctions: - Garantex Europe OÜ: US OFAC Specially Designated Nationals (SDN) List, Confirmed hit — entity GARANTEX EUROPE OU, programs CYBER4; RUSSIA-EO14024, matching Estonian Business Registration Number 14850239 (issued 18 Nov 2019) and both Tallinn addresses; aliases GARANTEX; websites garantex.io/garantex.org; listed BTC, ETH, USDT and TRX addresses; secondary sanctions risk per Section 11 of E.O. 14024 and 31 CFR 589.201. Originally designated 5 April 2022; re-designated under E.O. 13694, as amended by E.O. 14144 and E.O. 14306, on 14 August 2025 for facilitating ransomware actors and cybercriminals (over $100 million in illicit-linked transactions since 2019) https://sanctionssearch.ofac.treas.gov/Details.aspx?id=36025 - Garantex Europe OÜ: UK Sanctions List — The Russia (Sanctions) (EU Exit) Regulations 2019 (OFSI), Confirmed hit — GARANTEX EUROPE OU, Unique ID RUS1421, OFSI Group ID 15329, designated 4 May 2022; sanctions: asset freeze, trust services sanctions (imposed 21/03/2023) and director disqualification sanction (imposed 09/04/2025); statement of reasons: virtual currency exchange operating in the financial services sector in Russia, involved person supporting the Government of Russia; listed BTC, ETH and USDT addresses https://search-uk-sanctions-list.service.gov.uk/designations/RUS1421/Entity - Garantex (Garantex Europe OÜ): EU consolidated financial sanctions list (Ukraine regime), Confirmed hit — Garantex, type of entity crypto-currency exchange, designated 24 February 2025 under Decision 2025/389 (Council Regulation in the 16th sanctions package, the EU's first designation of specific crypto addresses; six associated wallet addresses listed). The EU entry records place of registration Moscow, Russian Federation for the Garantex exchange; the Estonian entity Garantex Europe OÜ is OFAC's and the UK's listed name of the same operation https://data.europa.eu/apps/eusanctionstracker/subjects/172907 - Garantex: Swiss SECO sanctions (Ordinance of 4 March 2022 on measures related to the situation in Ukraine, SR 946.231.176.72, annex 8), Hit for the Garantex exchange (listed 4 March 2025): asset freeze, travel ban, trade/financial/transport restrictions; recorded address Presnenskaya embankment 12, Moscow; page does not name the Estonian legal entity — treated as the same operation under its GARANTEX alias, listed with blockchain wallet addresses https://sanctions-finder.com/sanction/garantex-1/Garantex PEP: Adverse media: - 2022-03-10 [high] Estonian FIU supervision proceedings identified systemic and systematic AML/CFT deficiencies at Garantex Europe OÜ: over 90% of customers subject to breach of the duty to verify identity; customers presented as natural persons that were legal persons serving other customers with turnover of about €20 million to €100 million; failure to systematically notify FIU of suspicious transactions; property moved through the company related to crime or wallets used by criminal offenders. The company was authorised for virtual currency services from 27 November 2020 to 24 February 2022; FIU Director Matis Mäeker said annual transactions exceeded €5 billion, largely with Russia and other high-risk countries, and that the revocation would otherwise have followed https://fiu.ee/en/news/garantex-europe-ou-lost-right-provide-virtual-currency-services - 2022-04-05 [high] OFAC designated Garantex (Garantex Europe OÜ, registry number 14850239) as a ransomware-enabling virtual currency exchange pursuant to E.O. 14024 for operating in the financial services sector of the Russian Federation economy, in a coordinated action with Germany's takedown of Hydra Market https://home.treasury.gov/news/press-releases/jy0701 - 2025-03-07 [high] DOJ announced a coordinated operation with Germany and Finland against Garantex, which allegedly facilitated money laundering by transnational criminal organizations — including terrorist organizations — and sanctions violations, processing at least $96 billion in cryptocurrency since April 2019; on 6 March 2025 US authorities seized the domains Garantex.org, Garantex.io and Garantex.academy, German and Finnish authorities seized servers, and over $26 million in funds were frozen; administrators Besciokov and Mira Serda indicted in the Eastern District of Virginia; Garantex failed to register with FinCEN as a money transmitting business and redesigned operations to evade US sanctions, rotating wallets daily https://www.justice.gov/opa/pr/garantex-cryptocurrency-exchange-disrupted-international-operation - 2025-03-18 [high] After the multinational takedown, Tether froze approximately $28 million of the exchange's USDT; Garantex moved its customer base and funds to successor exchange Grinex, created by Garantex employees to support sanctions evasion https://crystalintelligence.com/investigations/garantex-shutdown-28m-freeze-whats-next-for-crypto - 2025-08-14 [high] OFAC re-designated Garantex Europe OU under E.O. 13694, as further amended, for directly facilitating ransomware actors and other cybercriminals (over $100 million in illicit-linked transactions since 2019), and concurrently designated successor Grinex, three Garantex executives and six associated companies in Russia and the Kyrgyz Republic; the State Department announced rewards of up to $5 million for Mira Serda and $1 million for other key Garantex leaders https://home.treasury.gov/news/press-releases/sb0225 - 2026-10-02 [high] US FinCEN special measures identify Garantex as a sanctioned prolific money launderer for Russian cybercriminals that moved funds to successor exchange Grinex after the March 2025 US law-enforcement action, associating it with the OFAC-designated 'A7 Network' https://opensanctions.org/entities/NK-ddgkduLoXLMdkW59mNmsKB Officers and owners: - Aleksej Besciokov: Garantex's primary technical administrator — maintained infrastructure, reviewed and approved transactions; charged with money-laundering conspiracy, conspiracy to violate IEEPA (sanctions) and conspiracy to operate an unlicensed money transmitting business (indictment unsealed 7 March 2025, EDVA); arrested in India (Lithuanian (Russian resident)) - Aleksandr Mira Serda (previously Aleksandr Ntifo-Siaw): Garantex co-founder and chief commercial officer; charged with money-laundering conspiracy (indictment unsealed 7 March 2025, EDVA); US State Department reward offer of up to $5 million for his arrest (Russian (UAE resident)) - Sergey Mendeleev: Garantex co-founder; shareholder of the Estonian entity (via Kihonzi Buzhaga OÜ records) until 10 March 2021; reportedly among the three Garantex executives designated by OFAC in August 2025; co-founded successor platform Exved - Stanislav Drugalev: Garantex co-founder; died in a car crash in 2021 - Iryna Chernyavskaya: null ### Stripe (recorded 2026-11-11) Input: Run a KYC screen on Stripe, Inc. in the United States Run record: high effort, 4.6 minutes, 15 pages cited. Risk rating: medium Rationale: Registration is clean and verifiable: Stripe, Inc. is a Delaware entity (registry no. 4675506, incorporated 2009-04-13) that was renamed and converted to STRIPE, LLC effective 2026-01-02, LEI 549300CLHGIPTCYHQ143 issued/ACTIVE with fully corroborated validation, headquartered at 354 Oyster Point Blvd, South San Francisco, CA, and consolidated under new parent Stripe Global Holdings Inc. (LEI 254900VYCQ4K0SLSXF22). Sanctions screening is negative: OFAC Sanctions List Search for 'Stripe' returned no matches and the SDN data file contains no 'Stripe' or 'Collison' entries; no officers are politically exposed persons (founders and board are private-sector executives). Adverse media is not clean but bounded: one resolved state regulatory settlement (Massachusetts AG, 2020, $120,000 over inadequate risk monitoring that let the PlexCoin fraud proceed - regulatory finding, severity high but closed), an open FTC debanking warning letter to CEO Patrick Collison (March 2026, no enforcement action yet), one ongoing consumer privacy class action that survived dismissal, open patent and fraud/conversion suits, merchant frozen-funds disputes (BBB logged 1,727 complaints over three years), and an allegation in an FTC receivership that Stripe violated an asset-freeze order. No criminal findings, no sanctions designation, no money-laundering conviction. The volume and variety of open civil and regulatory matters against a systemically significant payments company - plus regulatory scrutiny around its Bridge trust-bank expansion - supports a medium, not low, rating. Registration: STRIPE, LLC (previous legal name STRIPE, INC.) · 4675506 · United States - Delaware (US-DE) · ACTIVE (LEI registration status ISSUED; last update 2026-01-12, next renewal 2027-01-12) · 2009-04-13 · 549300CLHGIPTCYHQ143 https://lei.bloomberg.com/leis/view/549300CLHGIPTCYHQ143 Sanctions: - Stripe, Inc. / Stripe, LLC: OFAC SDN List and all other OFAC-administered sanctions lists (Sanctions List Search), No match - name search for 'Stripe' returned an empty Lookup Results table (SDN list last updated 11/9/2026) https://sanctionssearch.ofac.treas.gov/?SEQ=arrt+sanction+list - Patrick Collison; John Collison (founders/officers): OFAC Specially Designated Nationals list (full data file, 2026-11-11 retrieval), No entry for 'COLLISON' or 'STRIPE' in the SDN data file https://www.treasury.gov/ofac/downloads/sdn.csv PEP: - Patrick Collison: Cofounder and CEO, Stripe, Inc. - holds/held no prominent public function himself; flagged only as a potential close associate of a PEP: in 2026 he co-founded the Rhine Group, a policy forum and think tank, with former Italian prime minister Mario Draghi (a PEP by virtue of having held the prominent public functions of Italian Prime Minister and ECB President). No other Stripe officer, director or owner screened qualified as a PEP, family member of one, or close associate of one. https://en.wikipedia.org/wiki/Patrick_Collison Adverse media: - 2020-09-18 [high] Massachusetts AG announced Stripe, Inc. will pay $120,000 to resolve allegations that its risk monitoring and fraud prevention practices violated state consumer protection law by processing payments for Dominic Lacroix's PlexCoin (PlexCorp), a fraudulent and unregistered cryptocurrency offering (~$15M raised; at least 22 Massachusetts investors defrauded); settlement required enhanced security protocols, employee training and cooperation with investigations https://www.mass.gov/news/payment-processor-to-pay-120000-in-connection-with-cryptocurrency-scheme - 2026-03-26 [medium] FTC Chairman Andrew N. Ferguson sent a warning letter to Stripe CEO Patrick Collison stating that acts or practices to deplatform customers or deny access to financial services inconsistent with terms of service or reasonable expectations may violate the FTC Act and could lead to investigation and enforcement https://www.ftc.gov/news-events/news/press-releases/2026/03/ftc-chairman-andrew-n-ferguson-issues-warning-letters-ceos-paypal-stripe-visa-mastercard-about-debanking-american-consumers - 2021-07-28 [medium] Putative class alleges Stripe collected personal information including purchase data from visitors to merchant websites and shared it with other merchants and third parties under CIPA, Florida and Washington wiretap statutes; privacy, invasion-of-privacy and 'unfair' UCL claims survived the July 28, 2021 ruling https://courtdocket.org/stripe-lawsuit-privacy-patents-frozen-funds-and-ftc-warning - 2025-12-12 [medium] Autoscribe asserts U.S. Patent Nos. 11,620,621 and 12,462,234 against Stripe; case remains active https://courtdocket.org/stripe-lawsuit-privacy-patents-frozen-funds-and-ftc-warning - 2025-01-01 [medium] Alleges fraud, conversion, and violations of federal business-practices laws in how Stripe handles customer funds https://courtdocket.org/stripe-lawsuit-privacy-patents-frozen-funds-and-ftc-warning - 2024-08-14 [medium] The United States filed an ex parte application for an order pursuant to 28 U.S.C. 1782(a) against Stripe, Inc. in the Northern District of California; Magistrate Judge Kandis A. Westmore presiding https://unicourt.com/case/pc-db5-casegu83fc5d702353-1896097 - 2025-05-01 [medium] Court-appointed receiver alleged Stripe violated an asset-freeze order by processing an improper withdrawal and failed to transfer about $39,720 to the estate, seeking compliance and possible sanctions https://courtdocket.org/stripe-lawsuit-privacy-patents-frozen-funds-and-ftc-warning - 2025-12-04 [medium] Stripe froze roughly $1.45M held for nonprofit donation platform Flipcause, citing regulatory compliance concerns and Mastercard warning letters; bankruptcy counsel moved to compel release of about $790,000; Stripe cited potential exposure of up to $6M in chargebacks and fines https://courtdocket.org/stripe-lawsuit-privacy-patents-frozen-funds-and-ftc-warning - 2026-10-22 [low] BBB logged 1,727 complaints against Stripe over three years (692 in the last 12 months), predominantly concerning release of funds and account suspension/termination, with merchants reporting balances held indefinitely https://courtdocket.org/stripe-lawsuit-privacy-patents-frozen-funds-and-ftc-warning - 2024-05-01 [low] Plaintiff alleges Crumbl embedded Stripe's web-tracking technology to capture personal data without consent; frames Crumbl as aiding and conspiring with Stripe to violate CIPA https://courtdocket.org/stripe-lawsuit-privacy-patents-frozen-funds-and-ftc-warning - 2021-01-13 [low] Patent holder accused Stripe and Shopify of infringing three payment-escrow patents; Federal Circuit held the patents claimed only an abstract idea and were ineligible under 35 U.S.C. 101 - no finding against Stripe https://courtdocket.org/stripe-lawsuit-privacy-patents-frozen-funds-and-ftc-warning Officers and owners: - Patrick Collison: Cofounder and CEO; board member (Irish) - John Collison: Cofounder and President; board member (Irish) - Will Gaybrick: President, Technology and Business - Trish Walsh: General Counsel - Eileen O'Mara: Vice Chair - Jeff Titterton: Chief Marketing Officer - Steffan Tomlinson: Chief Financial Officer - Rob McIntosh: Chief People Officer - Tyler Bryson: Chief Revenue Officer - Claire Hughes Johnson: Corporate Advisor - Bill Winters, CBE: Independent Director - Group Chief Executive, Standard Chartered - Christa Davies: Lead Independent Director - Former CFO, Aon - Kevin Kelly: Independent Director - Partner, CIO, HRTG Partners - Luciana Lixandru: Independent Director - Partner, Sequoia Capital - Matthew Huang: Independent Director - Cofounder, Paradigm - Parker Conrad: Independent Director - CEO, Rippling - Francis Ryan: CEO and Director, Stripe Payments Company (California-registered operating entity) - Leland Rodger: Director and CFO, Stripe Payments Company - Mary Park: Secretary, Stripe Payments Company - Cassi Newell: Assistant Secretary, Stripe Payments Company - Patricia Walsh: Director, Stripe Payments Company ## 6. Questions ### What is an AI KYC screening agent? A research agent that assembles a know-your-business file from public sources. Nimble's agent finds the registered entity and its LEI, lists officers and owners from registry and beneficial ownership records, checks sanctions lists such as OFAC, UK OFSI, the EU and UN lists, looks for politically exposed persons, and triages adverse media by severity, then rates the business low, medium or high risk. ### How does it handle namesakes on sanctions lists? A name match is not treated as a hit until the date of birth, nationality, address or registry number lines up. Results that cannot be tied to the entity are dropped and counted as excluded namesakes. ### Can it replace my sanctions screening provider? No. Use it to prepare the file and to find what a list check misses, such as adverse media, related entities and ownership chains. Run names through your screening provider for the check of record. ### Can I run KYC screening from Claude, ChatGPT or my own agent? Yes. Paste this prompt into Claude, ChatGPT, Codex, Cursor or Grok: "Be my KYC research assistant using Nimble. Follow https://docs.nimbleway.com/skills/kyc-screening/SKILL.md." The skill asks what you need, connects Nimble if it isn't connected yet, and runs the agent. Developers can call the same ready-made agent by its ID from the API, the Python or TypeScript SDK, or from Mastra, LangChain, the Vercel AI SDK and LlamaIndex. ## 7. Skill The skill the prompt points to, as published at https://docs.nimbleway.com/skills/kyc-screening/SKILL.md (copied 2026-11-11). ### KYC screening Runs a sourced KYC / AML research screen on a company: registration, officers, beneficial owners, sanctions, PEPs and adverse media, with namesakes excluded and a risk rating. #### What the user gets Registry details, officers and owners, sanctions and PEP checks, adverse media, related entities, how many namesakes were excluded, and a risk rating with reasons. #### Agent template This skill runs the Nimble gallery template `kyc-screening`. The agent's instructions, sources and output schema live in the template. Do not rewrite them in the run. Effort: this skill runs the template at medium effort (about 1-3 minutes), even when the template's default effort is different. That is on purpose. If the user asks for a specific effort (low, medium, high or x-high), run that one instead. #### Flow 1. Interview the user. 2. Connect Nimble if it is not connected already. 3. Run the agent and show the result. 4. Offer next steps. Ask every question with the host's question UI, never as plain text: `AskUserQuestion` in Claude Code, ChatGPT's interactive question form (clickable choices and a Submit button) in ChatGPT. ##### Get the inputs | Input | Required | Ask for | If skipped | | - | - | - | - | | Company | yes | Legal or trading name | - | | Country | yes | Where it is registered | - | | Registry number or LEI | no | Removes namesake risk | matched by name and country | | Website | no | The company's domain. It confirms the right entity | no website given | * Skip anything the user already said in this conversation or in their request, and ask only for what is missing. Do not fill in answers from earlier conversations, with one exception: a stable fact about the user, such as what they sell, may be offered as the first option, labeled "(from before)". Never carry over the subject of the request, dates or rules from an earlier conversation. * Ask the required inputs first, in table order, one question at a time. Then ask the optional ones together, in one question-tool call, as many as the tool takes per call (a second call for the rest). * Put the whole question in the question tool, once. Never restate or introduce a question in text. Between questions, acknowledge the answer in a few words, and before the first question, at most one short sentence that acknowledges your role (the user's, if they named one), such as "Sure, I'll use Nimble to be your KYC research assistant." Talk in plain, friendly words: never say "input", "required" or "optional", and use no field names. Use plain text only if the host has no question tool, in one short line. * Write 2-3 likely answers as options, based on what the user has already said. Fixed examples in the table are a guide to what the answer contains, not a list to copy. Offer only answers Nimble can act on with public web data, never ones that need the user's own data, such as their customers or CRM. * If you cannot guess likely answers, such as a company name or an industry, still use the tool and offer two or three examples as options, written as answers the user could really give. If the user picks one, use it as their answer. * Every question must let the user type their own answer, optional ones too. Claude's question UI adds its own free-text choice ("Something else" in Claude, "Other" in Claude Code), so add none there. ChatGPT's form does not, so add "Other" as the last option of every question, even one whose options look complete, opening a text field with a placeholder. In any other host, add "Other" unless you know its UI already has a free-text choice. Keep Skip and Other, when you add them, even if you must drop an answer to fit the option limit. * Use single-select only. For a range, such as a size or a date, offer a few options that do not overlap. * Optional questions can be skipped, and a skipped answer uses the "If skipped" value. Claude's question UI has its own Skip button, so add no Skip option there. In other hosts, include a Skip option that states the default in its label, for example "Skip (any location)", not in the question. When you acknowledge a skipped question, say the default you will use, for example "Any location.", not that it was skipped. Do not offer a "skip all" option. If the user asks to skip the remaining questions, use the "If skipped" values for all of them. * Do not ask about effort. Build the agent input from this pattern: ``` Run a KYC screen on in . Registry number: . Website: . ``` Example: `Run a KYC screen on Greensill Capital in the United Kingdom` * One entity at a time. If the user names several, run the first and offer the rest next. Country is required. * A registry number or LEI makes the match exact. * Leave out any part of the pattern the user skipped: leaving it out is the default. ##### Connect Nimble Do this after the interview. Until the questions are done, say nothing about connecting Nimble. Check the connection. If a Nimble tool is listed in this session, call `nimble_agents_list`. If the CLI is available, run `nimble --client-source nimble-agent-skills agents list`. A normal response from either, even an empty list, means the user is connected: say nothing and go on. If neither check succeeds (no tool is listed and the CLI is missing or fails, or a check returns an auth error or an authorization link), connect it in these steps. Your message is only these steps: no summary of what the user told you, no mention of the skill, the template or the workflow, and no plan for what happens after connecting (that belongs in the run notice). 1. Tell the user, in two short sentences at most: "Nimble searches the live web and links where every answer came from. Connecting takes one approval, and if you're new to Nimble you start with a free trial." 2. Connect it in the first of these ways that works, and stop at the first one that does: * Show the host's card to connect or install Nimble from nimbleway.com: the Connect card for the connector in Claude, the install card for the plugin in ChatGPT. * If you can't show a card and a check returned an authorization link, show that link to the user. * If you can do neither but can run commands, follow [https://docs.nimbleway.com/agent-onboarding.md](https://docs.nimbleway.com/agent-onboarding.md) and involve the user only for the sign-up and the approval. With only the CLI and no `NIMBLE_API_KEY`, an approval is not enough: follow the page's API key fallback and have the user set the key in their environment, never in the chat. That page is written for you: never link it or its steps to the user. * If none of these works, tell the user how to find Nimble in this app, with the clicks: in ChatGPT, open Plugins in the sidebar, search for Nimble, pick the one described as "Expert web search for agents" and install it; in Claude, open Customize, then Connectors, then Nimble, then Connect. Never send the user to nimbleway.com for this. 3. Ask with the question tool, with the options "I've connected Nimble" and "Not now". If the host has no question tool, end the message by asking them to reply "connected", and add nothing after that. Never ask the user to paste an API key into the chat. When they confirm, check the connection again and go on without comment. If it is still not connected, say so in one line and ask again. If they pick "Not now", say the skill needs Nimble and stop. Show no research until Nimble is connected, not from your own search and not from memory. ##### Run the agent Do not comment on the connection check or on creating or reusing the agent. The first thing the user hears is step 2. 1. Create the agent from the template: `nimble_agents_create(template="kyc-screening", agent_name="kyc-screening")`. A 409 "already exists" means it was created before, so go on. If the template is not found, tell the user it is unavailable and stop. Do not substitute another template. 2. Tell the user once, in one line, what you are researching and how long it takes at the effort you will use: "Researching \. Expected to take \