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ARC-007CONFIDENCIAL · AnonimizadoALTO
Operation Atlas — OSINT due diligence of a strategic vendor prior to a multi-year contract
Independent reputational assessment of a European vendor candidate to a multi-year technology services contract (€3.6M over 3 years) with access to production infrastructure and sensitive data. Eight-layer OSINT-only due diligence surfaced six undisclosed material signals: opaque UBO across two jurisdictions, undisclosed director track-record with four dissolved entities, nine-month-old corporate domain with inconsistent narrative, postal address shared with 47 entities and a civil claim in the same sector. Medium-high risk. The client halted signing; the vendor withdrew after documentary requirements.
Analysis type
Reputational Due Diligence · Pre-contract
Sector
Corporate Intelligence · Manufacturing
Status
Closed · Contracting halted
Date
2025
Due DiligenceThird-party riskVendor assessmentProcurementUBO analysisAMLD5/6Sapin IIReputational intelligence
01
Context
- ·EU industrial group (€50–200M revenue), procurement with formal processes for strategic vendors.
- ·€1.2M/year contract over 36 months, with vendor access to internal systems and sensitive commercial data.
- ·Mandate: surface reputational, regulatory and operational risk signals prior to signing, OSINT only.
02
Methodology
- ·01 Corporate identity verification (BORME, Companies House, RCS, Handelsregister).
- ·02 UBO analysis under AMLD5/6 thresholds and detection of jurisdiction interposition.
- ·03 Sanctions screening (OFAC SDN/Consolidated, EU, UN, HM Treasury OFSI) and PEPs.
- ·04 Litigation and regulatory exposure (CENDOJ, BAILII, InfoCuria).
- ·05 Sector adverse media and reputation; 06 digital footprint (historical WHOIS, crt.sh, Wayback).
- ·07 Director background and cross-directorships; 08 linked-entity network by address/domain/phone.
03
Findings
01Opaque UBO across two low-transparency jurisdictions
ALTO02Undisclosed director track-record · 4 dissolved/insolvent entities
ALTO039-month-old corporate domain · inconsistent historical narrative
MEDIO04Postal address shared with 47 entities · address of convenience
MEDIO05Undisclosed archived civil claim · plaintiff in the same sector
MEDIO06No matches in restrictive lists · control finding
BAJO04
Operational impact
- ·Due diligence cost < 0.5% of the annual contract value evaluated.
- ·Avoided exposure: €3.6M over 3 years with a vendor whose real profile diverged from the declared one.
- ·Report archived as defensible documentary support for audit or future claims.
05
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