Use this record when due diligence raises a concern that could affect onboarding, contracting, work or payment. The relationship owner records the activity at stake. Compliance helps assess what the evidence supports. The person authorised under your policy decides what may proceed and records who will enforce any restrictions.

Use one relationship record and repeat the issue block for each concern. Keep documents and sensitive identifiers in the approved case system and cite their references here. These fields are a suggested workflow. Apply the organisation’s authority, confidentiality and escalation procedures.

Identify the next commitment

Start with the activity that could happen before the concern is resolved. A contract signature, start of work and release of payment may need different decisions. For an existing commitment, route restrictions through the people who can assess contractual and operational effects.

What to record Entry or evidence reference
Relationship ID, legal entity and identifying reference ____________________
Relationship owner, activity, jurisdictions and stage ____________________
Next proposed commitment, deadline and affected amounts or services ____________________
Decision authority and any conflicts of interest ____________________
Current restriction, evidence it is in place, operator and review time ____________________

Record one issue and the evidence needed

Write the fact that would affect the decision. Record what was observed, its source, and an alternative explanation where the evidence permits one. Distinguish a report or screening result from a verified finding. Use Supported, Concern, Unknown, or Not applicable with a reason. Blank means Unknown.

What to record Entry or evidence reference
Issue ID and specific proposition to establish ____________________
Observation, source and date, entity match and reliability limits ____________________
Evidence for or against, plausible alternative explanation and current status ____________________
Affected activity and exposure while the issue remains open ____________________
Specific evidence request, acceptable corroboration, owner and due date ____________________
Escalation route, receiving owner and deadline if evidence is late or contradictory ____________________

Record what may proceed and when

Choose Proceed, Proceed with conditions, Defer, Decline or Exit. Record a referral separately so it cannot be mistaken for clearance. Use a conditional decision only where policy permits it and the condition can be enforced before the exposure arises. If signature itself creates the exposure, a condition checked after signature comes too late. A policy exception needs a named authority, rationale, scope and expiry, and remains subject to applicable obligations.

What to record Entry or evidence reference
Decision, exact activity covered, authoriser, authority and date ____________________
Evidence relied on, open issues and rationale ____________________
Permitted activity and activity that stays restricted ____________________
Condition, evidence needed to clear it, verifier and deadline ____________________
System or manual hold, who operates it and who can release it ____________________
Action if a condition fails or expires, and any authorised exception ____________________

Follow the issue through to resolution or transfer

Keep the restriction and next review visible. Recheck the decision when a material fact changes, such as ownership, beneficiary, fees or delegates. Close as resolved once the evidence and disposition are recorded and any conditions affecting the issue are cleared. For a transfer, retain the linked case, the receiving owner’s acknowledgement and who controls every remaining restriction.

What to record Entry or evidence reference
Status (Open, Awaiting evidence, Awaiting decision, Monitoring conditions, Resolved or Transferred) ____________________
Next review, triggers, owner and actions if progress stalls ____________________
Resolution evidence and authority, or receiving case and acknowledgement ____________________
Remaining restriction, named operator and review date ____________________

Worked examples

These examples use fictional data.

A name match is resolved

Case TP-21. A report names a business with a similar trading name. Compliance compares the registration identifiers against registry extracts REG-21 and REG-22. The identifiers establish different entities. The relationship approver records that this alert is resolved and makes the onboarding decision after the remaining checks.

A fee recipient is unexplained

Case TP-22. A proposal allocates part of an intermediary’s commission to a separate company. The fee schedule identifies the recipient but gives no basis for its entitlement. Procurement seeks corroboration. The authorised owner defers signature and payment, and finance confirms hold H-22. A referral to investigations stays open while acknowledgement is pending.

A proposed condition comes too late

Case TP-23. A sponsor proposes signing now and checking a delegate before work begins. Legal identifies an obligation triggered at signature. Compliance records the delegate’s role as Unknown. The authorised owner defers signing. Procurement owns the evidence request. Signature can be reconsidered after the evidence is assessed or an enforceable alternative is approved within policy.

Sources behind the workflow