Scrutinex · Confidential
Entity Due Diligence Report
Prepared for a prospective commercial relationship
Overall assessment
Proceed with conditions
- Reference
- SCX-4B19C207
- Tier
- Full · Analyst reviewed
- Subject
- [REDACTED] Holdings Ltd.
- Issued
- 12 February 2026
Report type
Entity · Full review
Jurisdiction
Ghana
Review period
2015–2026
Sources checked
10 primary and specialist sources
Executive Summary
The subject is a valid, active company whose registration number, registered office and current filing status agree with the documents supplied. Neither the entity nor its three directors returned a match on the OFAC, United Nations or European Union sanctions lists reviewed.
Two matters should be resolved before funds are committed. One director appointed in 2023 could not be independently identified, and a second director held an undisclosed directorship in a British Virgin Islands company. Neither finding is evidence of wrongdoing; together, they create avoidable uncertainty around control and disclosure.
Key Findings
- 1
Subject entity is registered and active. Incorporated 2016; registration number and registered office match the documents supplied by the client.
- 2
Three directors of record. Two confirmed against national identity records. The third, appointed in 2023, could not be confirmed from any public source; the address on file is a company formation agent.
- 3
No match for the entity or any named officer on the OFAC SDN list, the OFAC consolidated non-SDN lists, the UN Security Council Consolidated List, or the EU Consolidated List.
- 4
One officer appears in the ICIJ Offshore Leaks Database as the director of a BVI-registered holding company incorporated in 2014 and struck off in 2019. The offshore entity is not disclosed in the subject's filings.
- 5
Two adverse media items located, both in local-language press. One relates to a contractual dispute settled out of court in 2021. The second names a similarly-named but distinct entity in a different jurisdiction and is not the subject.
- 6
Financial filings are current through the last statutory period. No insolvency, administration or strike-off proceedings on record.
Risk Drivers
Unverifiable director
A director of record whose identity cannot be confirmed from any public source, registered at a formation agent's address, is the single most common indicator of a nominee arrangement. It is not proof of one. It does mean you do not currently know who holds a third of the board.
Undisclosed offshore directorship
The offshore company is struck off and its officers are not published, so we cannot establish what it held or who else was involved. The material point is that the relationship was not disclosed in the subject's filings or in your negotiations.
Historic civil dispute
One settled contractual matter over ten years of docket history is within normal range for an entity of this size and sector. No pattern.
Recommended Next Steps
- 01Request a certified copy of the register of members and the appointment record for the 2023 director, directly from the company, before signing.
- 02Ask the second director, in writing, to describe the purpose and disposition of the BVI entity. The answer, or the absence of one, is informative.
- 03Structure the first two payments against delivery milestones rather than a schedule, until the board composition is clear.
- 04If either question is not answered within 14 days, commission an Individual Report on the unverified director before proceeding.
Sources & Verification Log
Every source consulted, in the order queried, with the date checked and what it returned. You can re-run any line in this table yourself.
| # | Source | Checked | Result |
|---|---|---|---|
| 1 | Registrar-General's Department, company file and annual returns | 2026-02-11 | Active; 3 directors of record |
| 2 | OFAC Specially Designated Nationals List | 2026-02-11 | No match (entity + 3 officers) |
| 3 | OFAC Consolidated Non-SDN Lists | 2026-02-11 | No match |
| 4 | UN Security Council Consolidated List | 2026-02-11 | No match |
| 5 | EU Consolidated Financial Sanctions List | 2026-02-11 | No match |
| 6 | PEP register (commercial aggregate, incl. close associates) | 2026-02-11 | No match |
| 7 | ICIJ Offshore Leaks Database | 2026-02-12 | 1 linked officer record (BVI, struck off 2019) |
| 8 | BVI Financial Services Commission, public entity search | 2026-02-12 | Entity struck off 2019; officers not published |
| 9 | National courts, civil docket search (2015–2026) | 2026-02-12 | 1 civil matter, settled 2021 |
| 10 | Adverse media scan, English and local language, 10-year window | 2026-02-12 | 2 items retrieved; 1 excluded as non-subject |