Check this letter.
OpusDatum's specimen findings letter and its risk-assessment record quote Mittenda's documents clause by clause. Every clause either of them quotes is listed below, with the document it comes from. The point of publishing a synthetic firm is that a reader can mark the work rather than take it, and that only holds if the quotations can be reached.
The two specimens are published with the rest of the pack at opusdatum.com/synthetic. The documents are here.
From the findings letter
Stage one, the coverage review. It reads the governing tier and nothing else, which is why 'Not evidenced' in that letter means the governing tier is silent.
| Finding | Clause | Document | |
|---|---|---|---|
| A | §6.2 | AML/CTF Policy (v4.2) Identity verified at onboarding against a reliable and independent source | MTD-POL-01 |
| A | §3.1, §6.1 | Transfers of Funds and Crypto-Assets Standard (v3.2) The accompanying fields enumerated: name, account, address | MTD-STD-04 |
| A | §3.5 | Transfers of Funds and Crypto-Assets Standard (v3.2) The deeming clause the finding turns on | MTD-STD-04 |
| B | §3.1 | Record Retention Policy (v1.4) Seven-year retention of transaction data | MTD-POL-02 |
From the risk-assessment record
Stage two. The governing tier carries over, and the operational tier enters where the assessed risk points, never estate-wide. That widening is visible in the table below: the procedures and the design note appear here and nowhere in the letter.
| Where | Clause | Document | |
|---|---|---|---|
| Criteria, evaluation | §5.1 | Risk Appetite Statement (v2.0) No appetite for breach of the obligations that admit no risk-based application | MTD-POL-03 |
| Identification | §3.5 | Transfers of Funds and Crypto-Assets Standard (v3.2) | MTD-STD-04 |
| Analysis, sources | §11.4 | Payments Operations Procedure (v3.1) Outbound fields populated from the Garnet account record | MTD-PRC-01 |
| Analysis, sources | §11.6 | Payments Operations Procedure (v3.1) Joint accounts default to the primary holder | MTD-PRC-01 |
| Analysis, sources | §7.2 | Crypto-Asset Transfer Operations Procedure (v1.7) The same population rule on the other rail | MTD-PRC-02 |
| Analysis, sources | §3.2 | Payment Platforms Design Note (v2.1) The account display label is customer-maintained in-app | MTD-TEC-01 |
| Analysis, sources | §6.2 | Payment Platforms Design Note (v2.1) Seven reconciliations, none joining the due-diligence record to the dispatched fields | MTD-TEC-01 |
| Analysis, evidence age | §4, §7 | Customer Due Diligence Standard (v2.0) Verification methods; the periodic review cycle and what resets it | MTD-STD-01 |
| Analysis, evidence age | §6.3 | AML/CTF Policy (v4.2) Verification refreshed on a change of identity information | MTD-POL-01 |
| Context | whole | Business-Wide Financial Crime Risk Assessment (v3.0, 2025 cycle) Read as context for the assessment, not quoted for a finding | MTD-RSK-01 |
From a document back to the finding
The index runs the other way too, for a reader who arrived at a document first.
| Document | Clauses quoted | Quoted in |
|---|---|---|
| MTD-POL-01 | §6.2; §6.3 | Letter, finding A; record, analysis |
| MTD-POL-02 | §3.1 | Letter, finding B |
| MTD-POL-03 | §5.1 | Record, criteria and evaluation |
| MTD-STD-01 | §4; §7 | Record, analysis |
| MTD-STD-04 | §3.1; §3.5; §6.1 | Letter, finding A; record, identification and analysis |
| MTD-PRC-01 | §11.4; §11.6 | Record, analysis |
| MTD-PRC-02 | §7.2 | Record, analysis |
| MTD-TEC-01 | §3.2; §6.2 | Record, analysis |
| MTD-RSK-01 | whole | Record, context |
Three documents in the estate are quoted by neither specimen: the Financial Crime Framework (MTD-FRM-01), the Transaction Monitoring Standard (MTD-STD-02) and the Sanctions Screening Standard (MTD-STD-03). All three were read, and being read and not quoted is an ordinary outcome of a coverage review. It is not the same as being irrelevant. A finding of 'Not evidenced' is a claim about what the whole governing tier does not say, so the documents carrying no quotation are part of what establishes it; a corpus is only the documents that get quoted if silence counts for nothing, and here it counts for a great deal.
What this page does not do
Each link opens the document, not the clause. The excerpts are published as PDFs, so a reader arrives at the top of the document and scrolls to the section named beside it. Anchoring a link to a clause would need HTML editions of the excerpts, which do not exist; saying so here is cheaper than implying a precision the page has not got.
The clause numbers are the documents' own. They are not regulation references: the provisions a finding is adjudicated against are cited in the letter and the record themselves.