完整案件證據

案件編號

CASE-BBDC997E62DF

版本

3

狀態

風險評估完成

司法轄區

TW

語系

zh-TW

市場設定

TW-DEMO-1.0

建立時間

2026-10-24T04:18:23.871012+00:00

更新時間

2026-10-24T04:20:11.637135+00:00

客戶資料

客戶編號

CASE-8F627936423C

投資人分類

尚未記錄

既有持有部位

尚未記錄

財務探索

目標與偏好

排序後目標

財富增值 · 資本保全

偏好幣別

TWD · USD · SGD

地區偏好

Global

產業偏好

尚未記錄

ESG 偏好

尚未記錄

禁止產品或市場

尚未記錄

風險輸入

意願

4

能力

4

知識

4

流動性

4

最大跌幅

15%

過去面對虧損時的反應

尚未記錄

已確認的客戶審查身分 · v1

客戶編號

CASE-8F627936423C

數值

Lin Wei-Chen · client

來源沿革

case 1 · transcript 1 · proposal 1 · review 1

受保護逐字稿投影 · v1

來源沿革

case 1

SHA-256

c9a0fd1e8c5b498e0b9ae6b739e813e1e5a00fd8f87de7d82ac5758fbab915d4

數值

13161 characters

## 1. Opening and purpose

**RM:** Thanks for making the time. Before we get into the account structure, I want to walk you
through why we ask the questions we're about to ask. Under the Money Laundering Control Act and
the FSC's onboarding requirements, we need to understand not just what you hold, but where it
came from — and for anything held through a company or a trust, who ultimately controls it. Some
of this will feel repetitive if you've done this at other banks, but bear with me.

**Client:** Sure, I've been through this before. Happy to help.

**RM:** Good. Let's start with identity, then move into your holdings, then your sources of
wealth. I'll flag anything I'll need to independently confirm as we go — that's normal, it's not
a sign of distrust, it's just how the file gets built.

**Client:** Understood.

**RM:** Full legal name as it appears on your national ID?

**Client:** It's Lin Wei-Chen on my ID — surname first, that's the standard order. Most of my
banking relationships list me as "Wei-Chen L." though, that's how it ended up in our CRM years
ago and it stuck.

**RM:** That's useful to flag now rather than later — I've seen name-order mismatches cause real
headaches when we're trying to match you across different registries and filings. I'll note both
forms on file.

**Client:** National ID is [NATIONAL-ID-REDACTED], date of birth [DATE-OF-BIRTH-REDACTED].

**RM:** Thank you. We'll verify that against your employer's records as part of the file, purely
as a cross-check — not because I doubt you, it's just part of how we resolve identity across
documents that might spell things differently.

---

## 2. Existing holdings — the direct stake

**RM:** Let's talk about what you hold. Starting with ABC Trading Co Ltd — what's your
relationship to that company?

**Client:** I'm a shareholder. I've held a stake since the company was set up — it's a trading
business, mostly electronics components, based here in Taipei.

**RM:** Do you know your percentage offhand?

**Client:** Twelve percent, directly in my own name. That one's straightforward, it's on the
shareholder register.

**RM:** Good — that's something we can confirm against the MOEA company registry filing directly,
so that part of the file builds quickly. Is that the extent of your interest in ABC Trading, or
is there anything else connecting you to it?

**Client:** *(pause)* That's the part that gets more complicated.

**RM:** Take your time. This is exactly the kind of thing I'd rather hear from you now than
discover later.

---

## 3. Relationships and ownership structure — the harder part

**Client:** There's a family trust. My father set it up years ago, before he passed — a lawyer in
Hong Kong handled it at the time, and honestly I've never dealt with that side of things
directly. I know it holds an interest in something connected to ABC Trading, but I couldn't tell
you the exact structure without asking our family's advisor.

**RM:** Do you know the trust's name?

**Client:** I believe it's called the W.C. Lin Family Trust. "W.C." for Wei-Chen — my father used
my name on it, which I've always found a bit strange since I wasn't really involved in setting it
up.

**RM:** And are you a beneficiary of that trust?

**Client:** I believe so, yes. I've never seen the trust deed itself.

**RM:** That's an important thing to be upfront about — I'll need to flag that as unconfirmed
until we can source the deed or an equivalent primary record. A trust with your name on it that
you can't confirm your own beneficiary status under is exactly the kind of gap our AML review
will ask about, so better we get ahead of it now.

**Client:** That's fair. I did hear at one point that the trust holds shares in a BVI company,
and that company has some stake in ABC Trading — but again, I'm going on memory of conversations
with the family advisor, not documents I've seen myself.

**RM:** Do you recall a name for the BVI entity?

**Client:** Something like "ABC Trading Holdings" — BVI-registered. I want to say it's called
ABC Trading (BVI) Holdings Ltd, but don't hold me to the exact wording.

**RM:** That's still useful — enough for us to search the BVI corporate registry directly rather
than relying on your recollection alone. Just so you understand why I'm pressing on this: Taiwan's
Company Act requires shareholder disclosure at a 10% threshold, but the AML Act's beneficial
ownership identification requirement kicks in at 25%. There's no central registry that aggregates
a person's total look-through interest across a chain like this — so if your direct stake plus
whatever comes through the trust and the BVI holding company adds up to something at or past 25%,
we need to be able to show our work, not just take your word for the total.

**Client:** I understand. I genuinely don't know if it adds up past that line — nobody's ever
walked me through the math.

**RM:** That's alright, that's what this process is for. I'll open a discovery trail on our side —
company registry filing, offshore registry search, BVI registry cross-reference — and we'll come
back to you only if something in the documents needs your input to resolve, like a discrepancy or
a name that doesn't clearly match.

---

## 4. Source of wealth — the 2019 share sale

**RM:** Let's move to source of wealth. Your stated total investable assets are around
NT$45,000,000. Walk me through where that came from.

**Client:** The largest piece is from 2019 — I sold a block of my shares in ABC Trading. That was
roughly NT$28,000,000.

**RM:** Was that transaction filed anywhere we could independently locate — a TWSE-style
ownership-change filing, a share transfer registration, anything like that?

**Client:** Yes, it would have gone through a formal share transfer filing at the time — my
accountant handled the paperwork. That should be a matter of record.

**RM:** Good, that's the kind of claim we can corroborate cleanly — a dated filing that matches
share count and timing does most of the work for us. What about the remainder?

**Client:** Salary. I drew a fairly standard executive salary from ABC Trading from about 20[DATE-OF-BIRTH-REDACTED], and I saved a meaningful portion of it rather than spending it. That accounts for
around NT$6,500,000.

**RM:** That we can check against employer-submitted income records for the period — again,
independent of anything you provide us directly.

**Client:** Makes sense.

---

## 5. Source of wealth — the rental income claim

**RM:** And the balance — roughly NT$4,000,000, if my arithmetic on the totals is right?

**Client:** That's rental income. I own a property in Taipei — well, I say "own," it's been in
the family a while — and it's been tenanted for years. The rent's been a steady supplement.

**RM:** Is the property titled in your name?

**Client:** *(pause)* I'd have to double check the exact title details. My cousin has handled the
tenancy side of things day to day — collecting rent, dealing with the tenant — for a long time
now. I get the income but I haven't personally touched the paperwork on that one in years.

**RM:** Do you have a lease agreement or rental statements you could provide?

**Client:** I can get you something from my cousin, but I'll be honest, I'm not sure how current
or complete it is.

**RM:** I appreciate you saying that plainly rather than papering over it. To be direct with you:
of everything we've discussed today, this is the item I have the least independent way to verify.
A share sale has a filing behind it. Salary has employer records behind it. Rental income on a
property you haven't personally handled the paperwork for, where the documentation may come only
from a family member — that's the profile of a claim that's harder for us to corroborate, and
it'll carry a correspondingly lower confidence in the file until something independent — a
property registry record showing you as the registered owner, ideally — closes that gap. I'd
rather flag that risk to you now than have it surface later as a surprise.

**Client:** I understand. I'll try to get you clearer paperwork, but I can't promise anything
beyond what my cousin has.

**RM:** That's a reasonable place to leave it for today. We'll run the property registry search
independently — if the title history tells a different story than what we've discussed, I'll come
back to you directly rather than let it sit as an unresolved flag.

---

## 6. Close and next steps

**RM:** Let me summarize what I've got, and you tell me if I've mischaracterized anything.

You hold a confirmed 12% direct stake in ABC Trading Co Ltd. There is a possible additional
interest through the W.C. Lin Family Trust and a BVI holding company, both unconfirmed pending
documentary review — which may or may not bring your aggregate look-through interest past the 25%
beneficial-ownership threshold. On source of wealth: a 2019 share sale (~NT$28,000,000, likely
well-evidenced by a formal filing), salary income 2015–2019 (~NT$6,500,000, checkable against
employer records), and rental income from a Taipei property (~NT$4,000,000, currently the weakest
link evidentially).

**Client:** That's accurate.

**RM:** Then here's what happens next, and it splits into two tracks. Some of this we can pull
ourselves, independently, without troubling you further. Some of it we can only get from you, as
documentary evidence — a registry search tells us what's on file, it doesn't hand us a certified
copy of your ID or a company's audited accounts. Let me separate the two.

On our side, we'll independently pull:

- the MOEA company registry filing for ABC Trading Co Ltd, to confirm the 12% direct stake and
  cross-check the name-order variant you flagged;
- an offshore registry search for the W.C. Lin Family Trust and its beneficiary status;
- a BVI corporate registry cross-reference for ABC Trading (BVI) Holdings Ltd and its stake in
  ABC Trading Co Ltd;
- the TWSE-style ownership-change filing for the 2019 share sale;
- employer-submitted income records for 2015–2019;
- a property registry search on the Taipei property behind the rental income claim.

From you, I'll need actual documents, not just today's conversation — a registry hit tells us a
filing exists, it doesn't stand in for the underlying paperwork an examiner would expect to see
in the file:

- a certified copy of your national ID, so identity verification isn't resting on what you told
  me across the table today;
- ABC Trading Co Ltd's annual financial statements for the last three years — audited, if they
  exist — so we can see the company's financial position independent of the share sale narrative;
- the trust deed for the W.C. Lin Family Trust, or whatever the family's Hong Kong lawyer can
  provide in its place — even a redacted or partial copy is more than we have now, and it's the
  single document that would let us stop treating your beneficiary status as an open question;
- any constitutional or incorporation documents you can obtain for ABC Trading (BVI) Holdings
  Ltd, since a BVI registry search confirms a stake exists but won't give us the underlying
  instrument;
- the 2019 share sale agreement itself, alongside whatever filing we locate — the filing confirms
  a transfer happened, the agreement is what shows us the consideration matches NT$28,000,000;
- title deed and lease agreement for the Taipei property, from your cousin if that's where they
  sit — given what you've told me about the title history, I'd treat this as the most urgent of
  the documents on this list.

None of this is a vote of no confidence in what you've told me — it's what turns a client
narrative into a file that holds up if a regulator asks us to defend it. Some of it, like the
trust deed, may take time to obtain; that's fine, we'll track it as outstanding rather than block
on it, but it will sit as an open item until it's in hand.

**Client:** That's a longer list than I expected, but I understand why. I can get you my ID
straightaway. The company financials and the BVI documents I'll need to go through our
accountant. The trust deed may take longer — I'll have to go through the Hong Kong lawyer, and I
honestly don't know how responsive that office still is. I'll chase the property paperwork with
my cousin this week.

**RM:** That's a reasonable pace, and thank you for being direct about where the friction is.
I'll log the trust deed and the property documents as the two to follow up on if we don't hear
back — those are also the two most load-bearing for the file, so it's worth pushing on them even
if they're slow to arrive. I'll flag anything our independent searches turn up that changes the
picture rather than waiting for every document to be in hand first.

**Client:** Understood. Thank you for being straightforward about the rental piece — I'd rather
know now if that's going to be a problem.

**RM:** That's exactly the right instinct. We'll be in touch on both tracks.

已審閱客戶脈絡 · v1

審閱者: adviser-demo · 來源沿革: case 1 · transcript 1 · proposal 1

• fact INTERVIEW_SUMMARY · accept
• party client_primary · accept
• party entity_reported_1 · accept
• party trust_reported_1 · accept
• party holding_company_reported_1 · accept
• relationship client_primary → entity_reported_1 · accept
• relationship trust_reported_1 → entity_reported_1 · accept
• relationship holding_company_reported_1 → entity_reported_1 · accept
• relationship client_primary → trust_reported_1 · accept
• SoW SOW_CLAIM_1 · accept
• SoW SOW_CLAIM_2 · accept
• SoW SOW_CLAIM_3 · accept

持股路徑 · v1

狀態: review_required · 0.0% confirmed · 12.0% potential · 來源沿革: case 1 / context 1 / proposal 1

實質受益人證據請求

無

實質受益人證據文件

無

實質受益人證據評估與沿革

資金來源主張 · v5

證據請求

證據文件

無

證據評估與沿革

法令遵循就緒狀態: ready_for_compliance_review

來源沿革: UBO 1 · SoW 5

• warning · sow_compliance_review — SoW claim SOW_CLAIM_2 requires compliance review.
• warning · sow_compliance_review — SoW claim SOW_CLAIM_3 requires compliance review.

客戶審查法令遵循決策 · v1

決策: approved · 目前有效核准: True

審閱者: compliance-demo

理由: Reviewed the SOW Claims 2 and 3 and satisfied with the documentation shared.

來源沿革: UBO 1 · SoW 5

版本

1

狀態

完成

最終風險屬性

成長型（growth）

最終風險等級

4

最高產品風險等級

4

規則版本

TW-WM-DEMO-1.1

來源探索版本

1

計算時間

2026-10-24T04:20:11.659947+00:00

投資期間／最大跌幅

84 個月 · 15%

評估維度

規則追蹤

尚未記錄

方案版本

1

驗證版本

1

產品目錄版本

US-CROSS-BORDER-REFERENCE-1.0

狀態

完成

提供者／模型

orchestrate_native · groq/openai/gpt-oss-120b

執行編號

5880fd77-5f54-4d6c-a84d-53d572b226b4

摘要

釐清問題

• 無

代理程式活動

1. #1 tool_complete — 取得案件資料 — get_case
2. #2 tool_complete — 取得投資組合限制與核准產品 — get_portfolio_context
3. #3 tool_complete — 驗證示範投資組合方案 — validate_portfolio_candidates_tool

尚未記錄

尚未記錄

尚未記錄