ScreenVeritAI
    TargetEuroTech Solutions GmbH
    Transaction€45M acquisition
    StatusScreening in progress
    RiskAssessing
    ScreenVeritAI · M&A Deal Roomclassification: demo · deal #2024-DEU-047
    M&A & Partnerships

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    §01Deal-room dashboard

    p. 01 / 09

    Deal #2024-DEU-047 — a €45M acquisition, mid due diligence. Financial and legal are done. Compliance is where deals die.

    Entity — acquisition target
    NameEuroTech Solutions GmbH
    CountryGermany (DE)
    IndustryTechnology
    Employees~340
    Transaction — deal parameters
    TypeFull acquisition
    Value€45,000,000
    TimelineQ2 2026
    Ref#2024-DEU-047
    Due diligence — status
    40%
    Financial DDDone
    Legal reviewDone
    Sanctions screenPending
    UBO / PEP checkPending
    Adverse mediaPending
    Risk assessment
    Pending
    Assessment running

    Compliance screen in progress

    §02Compliance — Layer 1 sanctions

    p. 02 / 09

    The surface check clears. The entity name is on no active list. That is the easy part — and the part that lulls buyers into signing.

    Compliance check — Layer 1
    Passed
    🇺🇸OFAC SDNPass
    🇪🇺EU ConsolidatedPass
    🇺🇳UN Security CouncilPass
    🇬🇧UK HM TreasuryPass
    🇦🇺Australia DFATPass
    🇨🇭Switzerland SECOPass

    6 of 6 lists clear · no direct sanctions matches on entity name

    Note: surface-level check only · ownership layer analysis pending

    §03Ownership — Layer 2 tracing

    p. 03 / 09

    Corporate layers exist to obscure control. Four jurisdictions later, the person behind the target comes into view.

    Ownership analysis — Layer 2
    Flagged
    🇩🇪EuroTech Solutions GmbH

    Germany

    Acquisition target
    🇨🇭TechHold AG

    Switzerland

    80% owner
    🇨🇾Meridian Investments Ltd

    Cyprus

    100% owner
    🇻🇬Eastern Capital BVI

    British Virgin Islands

    100% owner
    V. Sorokin

    UBO — PEP + connected to sanctioned entity

    100% beneficial owner

    PEP designation + indirect link to OFAC-designated entity

    Ownership graph — interactive view

    Exhibit — Ownership: EuroTech Solutions GmbH · M&A deep-dive
    PEP + Sanctions
    OWNS 60%OWNS 40%DIRECTORSUBSIDIARYUBO 100%EuroTech Solutions GmbHHolding A (Cyprus)Holding B (BVI)H. BeckerCEOMeridian Capital LtdFLAGGEDV. SorokinUBO · PEP + Sanctions linkCompanyPersonPEP / Sanctioned

    Key finding

    The beneficial owner, V. Sorokin, is identified as a Politically Exposed Person (PEP) and has an indirect connection to an entity designated under OFAC SDN. This finding does not appear in the surface-level entity check.

    §04PEP alert & enforcement precedent

    p. 04 / 09

    A politically exposed beneficial owner, indirectly linked to a sanctioned counterparty — the exact fact pattern behind the largest M&A compliance penalties on record.

    Alert — Layer 4Ownership chain — BVI entity

    PEP connection identified in ownership chain — V. Sorokin, Layer 4, BVI entity. Indirect exposure to OFAC SDN designated counterparty.

    Risk classification: Enhanced Due Diligence required before transaction proceeds.

    Comparable enforcement actions

    Ericsson AB

    DOJ / FCPA · 2022

    $1.06B

    Third-party due diligence failure

    Bribery through intermediaries with sanctioned-linked entities in Iraq. Compliance failures traceable to inadequate UBO screening of third-party agents.

    Airbus SE

    DOJ / SFO / PNF · 2020

    €3.6B

    Intermediary screening failure

    Systematic use of business partners and intermediaries without adequate screening across multiple jurisdictions including Middle East and Asia.

    Ericsson

    $1.06B

    2022

    Failed to conduct adequate due diligence on third-party agents used in M&A-adjacent supply chain acquisitions. FCPA violations traced to partners in Djibouti, China, and Vietnam.

    Inadequate partner due diligence

    Airbus

    $4B

    2020

    Paid bribes through business partners and third-party consultants across 20 countries. Due diligence on intermediaries was either absent or deliberately circumvented during deal execution.

    Inadequate partner due diligence

    §05Risk assessment — RAG matrix

    p. 05 / 09

    Every risk dimension, scored and cited. Green where it clears, red where it does not.

    Risk assessment — RAG matrix
    High risk
    G

    Direct sanctions exposure

    Entity not on any active list

    No direct matches
    R

    PEP exposure

    V. Sorokin — Layer 4 beneficial owner

    UBO is PEP
    R

    Indirect sanctions linkage

    UBO linked to SDN-designated entity

    OFAC connection
    A

    Corporate structure opacity

    BVI / Cyprus holding structure

    4 offshore layers
    A

    Adverse media

    UBO association findings

    3 relevant hits
    R

    Overall deal risk

    Enhanced Due Diligence required

    High risk

    §06Deal recommendation

    p. 06 / 09

    Not a verdict machine — a recommendation for the human who signs. Proceed, but only with enhanced due diligence and the conditions below resolved.

    Deal recommendation
    Proceed w/ EDD
    human review · hitl

    Transaction must not proceed without resolving the following conditions.

    Risk analysis identified PEP exposure and indirect sanctions linkage at the UBO level. Financial and legal DD are complete. Compliance DD requires escalation.

    01

    Obtain full disclosure on V. Sorokin's current PEP status and designations

    02

    Conduct enhanced background on the BVI holding entity Eastern Capital

    03

    Verify the nature of the connection to the OFAC-designated counterparty

    04

    Consider restructuring the deal to exclude or ring-fence problematic ownership layers

    05

    Obtain a legal opinion on regulatory implications for the acquiring jurisdiction

    Full report generated in 6 min 12 sec · sources cited · deal-room ready

    §07From term sheet to risk clearance

    p. 07 / 09

    Most screenings complete in under ten minutes.

    1

    Partnership proposal received

    Enter the entity name, jurisdiction, and any known principals — the platform accepts names in any script.

    2

    Deep research screening

    The AI checks sanctions lists, PEP databases, adverse media in 50+ languages, and corporate registries while tracing ownership chains automatically.

    3

    UBO graph review

    Review the ownership map — every entity and individual screened, with hidden connections and indirect exposures highlighted.

    4

    Risk committee presentation

    Export a board-ready evidence package with findings, source citations, ownership graphs, and a recommended risk tier.

    5

    Ongoing monitoring

    Post-closing, continuous monitoring alerts your team when the partner's sanctions status, PEP connections, or ownership structure changes.

    §08By the numbers

    p. 08 / 09

    Every

    Official source screened per partner

    ScreenVeritAI coverage

    50+

    Languages covered by AI adverse media research

    ScreenVeritAI multi-language engine

    <10min

    Average time to full partner risk profile with UBO graph

    ScreenVeritAI benchmarks

    §09Partner due diligence FAQ

    p. 09 / 09
    01When should we run partner due diligence screening?
    Before signing any binding agreement. Post-closing discovery of sanctions exposure triggers investigations and unwinding obligations that pre-deal screening prevents.
    02What information do we need to screen an M&A target or JV partner?
    At minimum, the entity's registered name and jurisdiction. Adding known principals, board members, or registration numbers improves accuracy.
    03How does ScreenVeritAI trace ownership through complex corporate structures?
    The AI maps ownership through holding companies, nominees, trusts, and cross-border structures — screening every entity and individual in the chain against sanctions, PEP, and adverse media databases.
    04Does the screening cover subsidiaries and affiliated entities?
    Yes. The screening covers the parent, subsidiaries, affiliates, and entities sharing common beneficial owners.
    05How is the evidence package formatted for deal rooms and boards?
    Timestamped report with risk findings, confidence scores, source citations, UBO graph, PEP details, adverse media summaries, and recommended risk tier — ready for deal rooms and regulatory filings.
    06What happens after the deal closes?
    Ongoing monitoring tracks changes in sanctions status, PEP connections, adverse media, and ownership structure. Your team gets automated alerts when the risk profile changes.
    07Can we screen multiple M&A targets or partners at once?
    Yes. Upload a CSV and the platform screens all targets in a single batch run with individual reports or a consolidated summary.
    08How does this relate to FCPA and UK Bribery Act compliance?
    Both laws hold you liable for your business partners' corrupt conduct. ScreenVeritAI identifies PEP exposure, bribery-related adverse media, and jurisdictional risk — the signals these compliance programs exist to detect.
    Key terms
    M&A Due Diligence
    The investigation and risk assessment conducted before completing a merger or acquisition, including sanctions, PEP, adverse media, and beneficial ownership checks.
    Joint Venture Compliance
    The obligation to screen JV partners for sanctions exposure, political connections, and reputational risk — JV partners can create direct sanctions liability for your organization.
    Third-Party Risk
    Compliance, financial, and reputational risk arising from business relationships with external parties — regulators increasingly hold you responsible for your partners' conduct.
    Beneficial Ownership
    Identifying the natural persons who ultimately own or control a legal entity, typically holding 25%+ of shares or voting rights.
    PEP (Politically Exposed Person)
    An individual holding a prominent public function — extends to family members and close associates, triggering enhanced scrutiny under anti-bribery regulations.
    Sanctions Exposure
    The risk that a business relationship creates a direct or indirect connection to a sanctioned person, entity, or jurisdiction — even when the immediate partner is not designated.
    Regulatory and industry sources
    1. 01
    2. 02
    3. 03
    4. 04
    5. 05
      EU Anti-Money Laundering Regulation (AMLR) 2024/1624

      Official Journal of the European Union

    Related workflows

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    Screen your supply chain for hidden ownership and risk exposure.

    Batch Portfolio Rescreening

    Rescreen your entire counterparty portfolio in a single batch run.

    API Integration

    Embed screening into your deal management workflow via REST API.

    chk deu-047svai-deal-roomv13 figures · demo

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