- Before
- “The questionnaire tells me what they want me to know. I need to see who's behind them.” Tracing an owner took weeks of registry pulls and slides.
- Now
- Opens the ownership graph as traced, with the tier, the answers it contradicts and every source one click away, and decides with conditions before the contract.
One distributor, from questionnaire to a signed decision
Minh Tran asks for Halvora Medical Trading Co., a distributor in Ho Chi Minh City, to take Corventa to public hospitals in four provinces, tender bids included — USD 2.4 million a year. Here is what happens next, screen by screen, in the working solution.
- 01Sep 29
The business asks for a distributor
Minh Tran · General Manager, VietnamMinh raises the request with term sheet v2 and his business reason. The risk scorer pre-screens it High — public hospital tenders in an Elevated-risk country — and the questionnaire goes out in Vietnamese and English the next morning. Halvora joins the register of 18 reviews with a 30-day clock, assigned to Dana Okafor.
Sponsor note: “Halvora is the only distributor with tender registrations in all four provinces before the November tender round.”
- 02Oct 7 · 06:52
The questionnaire is in — and it is only what Halvora declared
Dana Okafor · Third-party risk leadSixty-two answers, signed by the director Pham Quoc Bao. The graph shows what they say: Pham Quoc Bao 45%, Do Minh Chau 25%, and “other investors” 30%, not named in answer 3.1. A Singapore bank account asked for in 9.1 and three provincial resellers named “after signing” in 7.2 are already red flags. As declared, the score is 62 — Medium.
“This is only what Halvora declared.”
- 03Trace ownership
The anonymous 30% becomes a company, then a person
The agentsDana clicks Trace ownership and the graph grows node by node. The registry shows the 30% is Lotus Ridge Holdings Ltd., a British Virgin Islands company that took the stake in March 2022. The offshore record shows Lotus Ridge is 100% owned by Le Thu Hanh, born 1979, and has no other holding on record. The As traced bar climbs as each source lands.
Unknown owners are reported, never assumed.
- 04PEP match 0.93
Her husband sits on the tender board Halvora would bid to
Sanctions and PEP screenerLe Thu Hanh matches a PEP record on full name, year of birth and city: she is the spouse of Tran Van Khoa, Deputy Director of the Provincial Department of Health and a member of the provincial drug procurement and tender board since 2021. That board approves the results of medicine tenders for public hospitals in the province. The questionnaire answered “No” to government links.
“Rule fired: a government link makes a third party High.”
- 0507:03 · 11 sources
62 as declared, 82 as traced — High
Risk scorerSix weighted factors set the score: country 15 of 20, government touchpoint 22 of 22, compensation 20 of 20, ownership transparency 20 of 20, adverse media 5 of 10, sanctions 0 of 8. The graph moved three of them — ownership +10, government touchpoint +5.5, adverse media +5 — each with its citations. Seven red flags, every one opening its source passage beside the dossier.
Every factor is shown, from the approved scorecard version.
- 06The answers
Answer by answer, against the evidence
Questionnaire readerEach answer is a claim checked against the registry, screening and news. 3.1 and 4.2 are contradicted by the registry and the PEP record; 8.3 leaves audit rights “subject to discussion”, though policy requires them in every High-risk contract; 9.1 asks for payment outside Vietnam. 8.4 said “No” to any inquiry in five years, but Halvora was named in a 2024 provincial tender review.
“The questionnaire was signed by the director as complete and accurate.”
- 07Screening
Six subjects, four lists, 214 articles
Sanctions and PEP screener · Adverse media readerNo true sanctions matches across OFAC SDN, EU consolidated, UK and UN. Two name hits are proposed as false positives: Pham Quoc Bao on OFAC (born 1958 against 1974) and Le Thu Hanh on the EU list (1962 against 1979). In the news, the province cancelled a cardiovascular tender in March 2024 over bid-rigging complaints and reviewed three distributors, Halvora among them; inspectors closed it in June with no action.
“Dispositions are suggestions until you confirm them.”
- 08The term sheet
Margin, fees and the payment account against policy
Licence and terms checkerThe proposed 18% margin is outside the 8–12% Vietnam hospital benchmark, and the 3% tender success fee is not permitted under policy 4.3. A USD 120,000 marketing fund at the distributor's discretion needs a control, and the Singapore account is outside policy 6.1. At 18% plus the fee, Halvora would earn about USD 216,000 a year above the top of the benchmark with no stated service behind it.
- 09The decision
Approve only with conditions — 7 of 7 red flags mitigated
Dana Okafor · Third-party risk leadThe dossier writer maps each red flag to a condition: a written recusal or sale of the 30% stake before signing, no success fee, the margin capped at 12% with the marketing fund only against an agreed plan, payment only to Halvora's account in Vietnam, audit rights, an anti-bribery clause with a corrected questionnaire and annual certification, the resellers named, and quarterly monitoring. Untick one and the screen shows which flag is left open.
Agent recommendation: “Approve with conditions — only if the recusal or sale of the 30% stake is in writing before signing. Otherwise reject.”
- 10E-signed
Signed, with the clause pack written for legal
Dana Okafor · then Lena OrtizDana signs with the meaning “I approve this third party with the conditions listed”. The eight conditions become contract clauses for Lena Ortiz, legal counsel, to approve; Priya Raman in procurement releases the vendor in the ERP only after contract signature. Halvora goes on daily monitoring, payments checked against the 12% cap, with a re-review due Oct 7, 2027.
If a red flag is left open, the approval goes to Omar Haddad, Chief Compliance Officer, as an exception.