Case: Due Diligence of a fintech startup before its Series B — AML risks identified
Context: a leading venture fund was considering a 5M Series B investment in a fintech startup (payment gateway, present in 12 countries).
Methodology:
- Full OSINT audit of beneficiaries and key people (5 jurisdictions)
- Analysis of transaction monitoring over 24 months
- Checks against sanctions lists (OFAC, EU, UK, UN, Russia)
- Screening of counterparties and merchants through World-Check and Refinitiv
- Technical audit of the infrastructure: APIs, data security, PCI DSS
Key findings:
- The CEO holds a hidden stake in an offshore structure (BVI) that receives payments from high-risk merchants
- 12% of transaction volume went through wallets flagged by Chainalysis as mixer or darknet market
- The KYC policy does not meet 5AMLD: no enhanced due diligence for PEPs and offshore entities
- Two key investors have a history linked to money laundering cases
Recommendation: do not invest. The fund declined — saving 5M and reputational risk.
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