Prime Trust FIU and CDD Teams Drive Complex Investigations With Sayari
Industry: Cryptocurrency Infrastructure
Use Cases: Financial Intelligence Investigations and Customer Due Diligence (CDD)
Customer Due Diligence Struggles with Data Scarcity
Prime Trust is a digital asset infrastructure provider and a regulated trust company, chartered in the state of Nevada. One of Prime Trust’s core use cases is helping startups and other crypto businesses enable fiat-to-crypto on- and off-ramps. To maintain its reputation as a safe and compliant custodian of crypto tokens, Prime Trust runs prospective customers through a rigorous due diligence protocol and investigates any entities that display red flags for money laundering and financial crime risk as part of its transaction monitoring.
As an emerging market, cryptocurrency attracts high-risk entities and illicit actors. Prime Trust mitigates this risk by putting all prospective customers through a thorough screening process that involves checks in platforms like LexisNexis and Castellum as well as open-source data.
In early 2022, however, Prime Trust’s onboarding team began to encounter entities with problematically scant data profiles. “Especially in the Latin American region,” says Senior Client Due Diligence Analyst Billy Berg. “It was hard to find even open-source information about their connections or business dealings.”
Prime Trust’s Chief Compliance Officer, Nirvana Patel, led the search for a software solution capable of providing the comprehensive insight necessary to diligence these more opaque commercial entities and selected Sayari.
So yes, we’re trying to meet customer expectations and be fast and efficient, but we’re also trying to remain compliant and keep everyone safe in an increasingly dangerous and ambiguous world.
— Brad Epstein, SVP Financial Crimes Compliance
We turned away 20 different entities based on findings from Sayari. That’s quite a high number.
— Brad Epstein, SVP Financial Crimes Compliance
Prime Trust Forestalls Regulatory Risk, Enhances Investigative Efficiency
Offering commercial risk intelligence data on 450M+ companies and 512M+ key individuals in over 250 jurisdictions worldwide, the Sayari Graph platform empowers investigative teams to confidently investigate global counterparty networks.
Since adopting Sayari Graph, Prime Trust’s CDD team has used the platform to deny more than 20 high-risk entities. A dozen of these were based in the Latin American region and had hidden ties to the sanctioned Maduro government in Venezuela. According to Berg, these entities were attempting to evade sanctions by establishing banks offshore and using either Fedwire, ACH, or cryptocurrency payment rails to funnel money out of Venezuela.
The team quickly denied the first of these companies for links to Maduro and possible money laundering risk. Not three months later, however, another entity based in Latin America attempted to onboard — and this time, it made more of an effort to disguise its illicit nature.
“This second company,” Berg recounts, “didn’t disclose in its beneficial ownership statement that one of its owners also had a hand in running the company we had previously denied. His ownership stake didn’t meet the reporting threshold, but we were able to uncover the illicit connection through Sayari.”
In a separate case, a company looking to onboard intended to use cryptocurrency for nontraditional purposes in the Middle East. The primary owner of this company provided a Cypriot passport, but the CDD team discovered using Sayari Graph that he was actually a Russian national and suspected arms dealer.
Meanwhile, Prime Trust’s Financial Intelligence Unit (FIU) has leveraged Sayari in its transaction monitoring investigations, using the platform’s cross-border networks to identify customer counterparties that do not surface in other open-source searches. Visibility into international jurisdictions has led to the off-boarding of a number of high-risk customers and helped Prime Trust avoid potential regulatory scrutiny.
The ability to share corporate network diagrams in Graph has empowered the CDD team to hold coaching sessions with other internal teams – particularly Sales – on the types of compliance risks attempting to onboard. Through these sessions, CDD has been able to equip customer-facing teams with the screening techniques they need to catch these risks before they reach the onboarding stage. This has reduced dramatically the amount of time and effort wasted on prospects that would never become customers.
Sayari Forges Personalized Partnership with FIU and CDD Teams
To help Prime Trust’s CDD and FIU teams take full advantage of the platform, Sayari analysts led them through a customized workshop investigating some of the entities they had struggled to profile using their other systems.
Ali Lakhani, Prime Trust’s Director of Client Due Diligence, says the workshop revealed just how much information Sayari had to offer on these hard targets. “It really helped us take our investigations to the next level.”
With plans to book a second workshop, Prime Trust’s investigators maintain close ties with Sayari analysts, reaching out on Slack with questions as they arise. Lakhani maintains that this kind of personalized partnership has had a significant effect on the company’s success with the platform. “It’s like night and day from a lot of other vendors that we work with.”
Prime Trust is also laying the groundwork to integrate Sayari Graph more tightly with its systems so that basic due diligence checks can happen early and automatically.
“Beyond fines and reputational risk,” says Brad Epstein, Prime Trust’s SVP of Financial Crimes Compliance, “it’s important to remember that a lot of these sanctioned individuals are actively exploiting their countries’ populations, siphoning off resources and laundering that money through institutions. You can’t put a price tag on what that does to a country or its people.”
“So yes, we’re trying to meet customer expectations and be fast and efficient, but we’re also trying to remain compliant and keep everyone safe in an increasingly dangerous and ambiguous world.”
His ownership stake didn’t meet the reporting threshold, but thankfully, we were able to uncover the illicit connection through Sayari.
— Billy Berg, Sr. Onboarding Analyst
Sayari empowers regulators and investigators to mitigate risk exposure and fight financial crime by providing instant visibility into commercial networks worldwide.
Its flagship solution, Sayari Graph, harvests billions of public records from over 200 jurisdictions to deliver a global database of ownership hierarchies, commercial relationships, and risk analyses—available via web application, API, or data subscription.
Since its founding in 2015, Sayari has earned the trust of top financial institutions, Fortune 100 corporations, and government agencies, securing a $40M Series C in 2021. Sayari is headquartered in Washington, D.C., and its solutions are used by more than 3,000 frontline analysts in 35 countries.