Check new clients – with evidence for the supervisor.
Lena checks client file, commercial register, Transparency Register and sanctions lists against anti-money laundering law. She shows where you need to look more closely – every statement with its source.
Each source looks harmless – only together do they show the risk.
Client file, commercial register, Transparency Register, sanctions lists and the Anti-Money Laundering Act: for every client check you pull it all together by hand. And when supervisors or auditors ask why you onboarded the client, the reasoning has to be traceable.
The question
You ask Lena – in one sentence.
Instead of building reports, you simply ask. Lena shows what gets checked – step by step, across all sources.
The evidenced answer
Every finding comes with its citation.
Every statement names the source it comes from. Whatever can't be evidenced, the agent marks as open.
The next step
Lena prepares – you approve.
Lena prepares the next step. It is only carried out once you approve it.
Hi, I'm Lena – your AI agent for finance & compliance. I keep an eye on your systems and speak up when something stands out.
I noticed four signals today – each inconspicuous on its own:
Signals · today
SharePointClient file Nordwerk Logistik
c:node GraphCommercial register: HRB 48213
c:node GraphHolding outside the EU owns 62 %
c:node GraphSimilar name on EU sanctions list
@Lena, can we onboard Nordwerk Logistik GmbH as a new client – properly under anti-money laundering law?
I'm checking all sources:
Read the client file (4 documents)
Matched company name, seat and register number with the commercial register
Identified beneficial owners in the Transparency Register
Screened against the EU financial sanctions list
Checked obligations under GwG §§ 10, 15
Onboarding possible – but only with enhanced due diligence.
Company name, seat and register number match the commercial register
Holding outside the EU owns 62 % – establish beneficial owners down to the natural person, enhanced due diligence (GwG §§ 10, 15)
Similar name on the EU financial sanctions list (84 %, different year of birth) – probably a false positive, clear it before onboarding
Draft · Query to Nordwerk + enhanced due diligence
Query to Nordwerk Logistik GmbH: documents on the holding and on the beneficial owners down to the natural person, plus the director's date of birth to clear the sanctions hit. The case is set up for enhanced due diligence.
ApproveEditNothing goes out without approval
Example case with sample data · real legal bases · not legal advice.
c:node Research · Finance & Compliance
Why AML client checks take so much manual work — and how traceable AI evidences every step.
Reading time ~6 minBasis 10 sources, verifiedTopic Anti-money laundering & client checks (KYC)Approach evidenced with sources · on-prem capable
Fig. 0 · A client check draws on the client file, registers, sanctions lists and the law — the risk only shows once you connect them.
Summary
Anyone onboarding a new client must know, under the German Anti-Money Laundering Act (GwG), who they are dealing with, who owns the company and whether there is a higher risk. The answers are scattered: in the client file, the commercial register, the Transparency Register, on sanctions lists and in the law itself. This article shows, with sources, why checklists and generic AI reach their limits here — and how c:node connects the sources, evidences every finding and leaves an audit trail for supervisors and auditors.
1 The problem: the signals sit in many data silos.
The German Anti-Money Laundering Act requires general due diligence for every new business relationship: identify the contracting party and establish who is behind it economically — down to the natural person.1 If you identify a higher risk, enhanced due diligence applies, for example where high-risk third countries are involved.2 The information you need sits in many places: company name and seat in the client file and the commercial register, the beneficial owners in the Transparency Register,3 names on the consolidated EU financial sanctions list.4 Each source looks harmless on its own. Only together do they show whether you need to look more closely. And later, supervisors or auditors ask: why did you onboard this client?
2 Why checklists and generic AI don't solve this reliably.
An Excel checklist records that something was checked — but not what the sources add up to. Querying registers and lists by hand means copying results from one window to the next, and the connection gets lost. And an AI chatbot? The US standards institute NIST states that fabricated statements are inherent to the design of such models.5 Without access to your client file and the registers, a generic model cannot check the specific client anyway. Even when the AI searches real documents, the error rate only drops — it does not disappear.6 For a decision you have to justify to your supervisor, that is not enough.
3 The approach: client, registers, sanctions lists and law in one graph.
c:node links your client file with the c:node Graph — commercial register, Transparency Register, sanctions lists and the Anti-Money Laundering Act as a network of points and edges: a knowledge graph. Research calls this combination of pattern recognition and firmly checked rules neuro-symbolic AI; it delivers answers you can justify and trace.7 Across the graph, c:node reasons several steps ahead — client → holding → director → sanctions list entry — which plain text search cannot do.8 Every step stays tied to its source.
:nodeGraph— Client checklive
Source (API)EntityHitRule / evidence
Nodes active · edges fire in real timeisolated per tenant · grows with every check
Fig. 1 · Client file, registers and sanctions list connect via the holding to the open hit. c:node fires the path — every step stays tied to its source and to the legal basis in the Anti-Money Laundering Act.
4 In practice: scattered sources become a well-founded decision.
The same question for which you query registers and lists one by one today, c:node answers in a single pass — and discloses every statement:
Can we onboard Nordwerk Logistik GmbH as a new client – properly under the Anti-Money Laundering Act?
Onboarding possible – but only with enhanced due diligence. Company name, seat and register number match the commercial register. A holding outside the EU holds 62 % of the shares: you need to establish who ultimately owns the company, down to the natural person. A director of the holding resembles an entry on the EU financial sanctions list (84 % name match, different year of birth) – probably a false positive, but it must be cleared before onboarding. Recommendation: start enhanced due diligence and prepare the query to the client.
5 Auditable for supervisors and auditors — and sovereign.
The Anti-Money Laundering Act requires you to record the information gathered during the client check and the result of the risk assessment, and generally to keep it for five years.9 c:node stores every finding with its source and legal basis. This creates an audit trail you can show your supervisor, such as BaFin, or your auditors — without disclosing the inner workings of the model. Your team still makes the decision; c:node prepares it. From 10 July 2027, the EU Anti-Money Laundering Regulation (EU) 2024/1624 will also largely apply directly in all member states;10 you connect new obligations in the graph instead of rebuilding checklists. And because c:node runs in the EU cloud or on your own servers, client data stays in the EU or in your own data centre.
In short: the risk does not sit in one source but in their connection. c:node makes that connection — and turns scattered register extracts into a well-founded decision you can show your supervisor. So you decide on new clients faster and on firmer ground.
Sources
German Anti-Money Laundering Act (GwG) § 10 — general due diligence: identifying the contracting party and the beneficial owner (German). gesetze-im-internet.de…
German Anti-Money Laundering Act (GwG) § 15 — enhanced due diligence where the risk is higher (German). gesetze-im-internet.de…
German Anti-Money Laundering Act (GwG) § 20 — information on beneficial owners for the Transparency Register (German). gesetze-im-internet.de…
European Commission — consolidated list of persons, groups and entities subject to EU financial sanctions. finance.ec.europa.eu…
NIST, Artificial Intelligence Risk Management Framework: Generative AI Profile (NIST AI 600-1), 2024 — fabricated statements are inherent to the design. nvlpubs.nist.gov…
MEGA-RAG (Multi-Evidence RAG) — retrieval cuts fabricated statements by over 40 % but does not eliminate them. PMC12540348, 2025. ncbi.nlm.nih.gov…
Hitzler et al. (eds.), Handbook on Neuro-symbolic AI and Knowledge Graphs, IOS Press, 2025. iospress.nl…
GraphRAG-Bench — graph-based AI outperforms plain text search in multi-step reasoning. arXiv:2506.02404, 2025. arxiv.org…
German Anti-Money Laundering Act (GwG) § 8 — record-keeping and retention, generally five years (German). gesetze-im-internet.de…
Regulation (EU) 2024/1624 of 31 May 2024 (EU Anti-Money Laundering Regulation, AMLR) — largely applies from 10 July 2027. eur-lex.europa.eu…
The sources support the principles (limits of generative AI, retrieval reduces errors, neuro-symbolic approach, multi-step reasoning) and the legal bases (Anti-Money Laundering Act, EU financial sanctions list, EU AML Regulation). Names, register number and figures in the live graph and the example dialogue are sample data, not real cases. This article is not legal advice.
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