FLIORE for compliance officers: from control to evidence
Updated: 2026-09
The compliance function rarely fails on diligence but on demonstrability. What counts is a process that produces the evidence as a by-product rather than requiring it to be reconstructed afterwards.
Anyone responsible for compliance in a family office or trustee practice works against an uncomfortable asymmetry. Diligence is applied daily but assessed only in the exceptional case — an audit, a supervisory review, a bank enquiry. And what is assessed then is not the diligence but its documentation.
The second point is dispersion. The onboarding file sits in one place, screening results in another, the deadline list in a spreadsheet, the correspondence in a mailbox. There is an answer to each individual question, but the connection must be re-established by hand every time.
Then there is cross-border assessment. Who counts as a beneficial owner depends on the jurisdiction, and the relevant thresholds diverge. Keeping that assessment correct and documented per beneficial owner is the most labour-intensive part of the function.
How it works
- 01
Run onboarding as a system flow rather than email
Handle taking on a mandate with all its evidence in the system; the audit trail then arises as a by-product rather than an extra task.
- 02
Assess beneficial owners per jurisdiction
For each beneficial owner, record the governing jurisdiction and document the assessment under its rules — the thresholds differ considerably.
- 03
Make disclosability and enhanced due diligence visible
Show per mandate who is disclosable and who requires enhanced due diligence as a politically exposed person, rather than reconstructing it case by case.
- 04
Bind periodic reviews to the mandate
Keep due controls where the mandate sits, so the deadline overview does not depend on a separately maintained list.
- 05
Store evidence versioned and access-controlled
Keep screening results, identification documents and resolutions in the encrypted vault, versioned and mandate-bound.
- 06
Test the audit trail before the review
Spot-check whether, for any given mandate, it can be evidenced without gaps who changed what and when — before the audit, not during it.
Why it fits here
FLIORE assesses each beneficial owner against the rules of their own jurisdiction — among them the EU’s 25 per cent threshold, 10 per cent in India, 5 per cent in South Africa, the Swiss regime and the US Corporate Transparency Act.
The audit trail arises from the workflow rather than as a separate documentation task; that is the difference between evidenced and asserted diligence.
FLIORE AI answers only from the mandate’s data and cites its sources — in a compliance function, an unevidenced answer is worthless.
FAQ
Is FLIORE legal advice?
No. FLIORE is decision support for the responsible compliance function. The assessment and the responsibility stay with the person accountable.
How are differing UBO thresholds handled?
Each beneficial owner is assessed against the rules of their own jurisdiction. Per mandate it shows who is disclosable and where enhanced due diligence applies.
What does the audit trail do in a review?
It records who changed what and when. That makes it evidenceable that a control took place — not merely that it was intended.
How are politically exposed persons identified?
FLIORE shows per mandate who requires enhanced due diligence as a politically exposed person. The resulting measures rest with the compliance function.
Is client data used for AI training?
No. FLIORE AI answers only from the data of the mandate in question, cites its sources, and never trains on client data.
FLIORE
FLIORE assesses each beneficial owner against the rules of their own jurisdiction — among them the EU’s 25 per cent threshold, 10 per cent in India, 5 per cent in South Africa, the Swiss regime and the US Corporate Transparency Act.
The audit trail arises from the workflow rather than as a separate documentation task; that is the difference between evidenced and asserted diligence.
FLIORE AI answers only from the mandate’s data and cites its sources — in a compliance function, an unevidenced answer is worthless.