CH / BLOG / 01 - Checks on people

What a check on an individual shows before entering a partnership

A CV and references show the version a person tells about themselves. A check shows what remains of that version after comparison with independent sources - and, more importantly, where exactly you are making a decision on the basis of an assumption rather than a confirmed fact.

Время чтения: 17 minutesBLACKFILE editorial team

Two business partners and an adviser reviewing printed materials at a table in natural light

BLACKFILE editorial teamОпубликовано: 18 марта 2026Обновлено: 5 августа 202617 minutesИсточники проверены 05.08.2026How we work

Short answer

Checking a person before a partnership is not a search for compromising material - it is a comparison of the stated version with independent sources across five areas: identity, career, connections, significant events and reputation.

A great deal can be established lawfully: confirming identity and eliminating name matches, verifying the biography and positions against registers and publications, reconstructing corporate roles and shareholdings, checking court, regulatory and sanctions mentions, and assessing public reputation against primary sources. All of this is done using open and officially accessible data.

But a check does not pass a verdict. Litigation, PEP status, a complex ownership structure or a negative publication are indicators requiring explanation, not proof of guilt. The result of an honest check is not a rating of "reliable or not", but a map: what is confirmed by a document, what has been reconstructed from the body of data, what remained inaccessible, and which questions should be put to the person before you tie capital, reputation or a business to them.

Механика

Map of an individual check

Five lines of enquiry from identity to conclusion. Each builds on the previous one; the level marked in red is where information moves from fact to analytical conclusion.

01 / IDENTITYIdentityWhether this is the right person: stable attributes, elimination of name matches.
02 / CAREERCareerBiography, education, roles - verified against registers and confirmations.
03 / LINKSConnectionsCorporate roles, shareholdings, previous projects and related persons.
04 / EVENTSEventsCourt, regulatory and sanctions references and PEP status.
05 / OUTPUTConclusionFact, assessment, hypothesis and questions for the individual - kept separate.

Красным отмечен уровень вывода: факт, оценка и гипотеза разделяются

Area 1 · Basis

Why a check is needed and on what legal basis data is processed

A partnership ties you to a person more closely than a one-off transaction. A shared business, access to money and information, signing authority, a reputation now shared by two parties - all of this works while the parties are who they presented themselves to be. A CV, references and first impressions describe a person in their own words. This is not deception by default, but it is a version, not a verified fact. A check before a partnership answers a simple question: what remains of that version once it is compared with sources the person does not control.

The processing of personal data in such a check within the European legal framework rests on a lawful basis. The EU General Data Protection Regulation permits processing without the subject's consent where it is necessary for the purposes of a legitimate interest, and where that interest is not overridden by the person's rights and freedoms. Checking a prospective partner, counterparty or director is a typical example of such an interest: the party has a genuine business need to assess risk before taking a decision.

Legitimate interest is not an unconditional permission. It requires proportionality: only what relates to the business assessment is collected, from sources to which there is lawful access, and in a volume justified by the significance of the decision. A check before entering a joint business involving a large sum and a check on a casual acquaintance are tasks of differing permissible depth. The European Data Protection Board addresses in separate guidance how the legitimate interest test is applied and where its limits lie.

The practical consequence for the client: a properly conducted check not only answers the question of "what kind of person is this", but also stays within legal limits, so that its result can be used - in negotiations, in the structure of an agreement, in a decision not to enter into a transaction. Material collected by impermissible means is useless precisely when it is needed most.

What a lawful check rests on

  • the business necessity of assessing risk before a significant decision
  • open and officially accessible data sources
  • proportionality of the volume of data to the significance of the decision
  • separating business interest from curiosity about private life
Area 2 · Identity

How to establish that you are checking the right person

The most common and least visible error in checking a person is faultlessly performed work on the wrong individual. Full namesakes occur more often than one might think, and on a national scale a common first and last name will have dozens of bearers. A single name match with a party to court proceedings or an entry on a sanctions list is enough for an honest person to be wrongly recorded as high-risk - and, conversely, for the subject's real problems to be lost among other people with the same surname.

A name, a city and an approximate age are weak identifiers. Reliable identification is built on stable attributes and their intersection: a confirmed date of birth, documented roles in companies with precise registration details, professional registrations, and a consistent history that links episodes of the biography into a single line. A single attribute is easily wrong; the coincidence of several independent attributes sharply reduces the likelihood of misidentification.

A separate check establishes whether the person in the negotiations is the same person as in the documents. Sometimes one person represents a party to a transaction while another signs and assumes the obligations. In itself this is lawful - a representative, a power of attorney, a role within a group - but from the standpoint of your rights, what matters is the person named in the documents, not the one who was charming at the meeting.

A feature that requires attention is breaks and changes. A change of surname, a move between jurisdictions, long unexplained gaps in a biography are lawful and commonplace. But they interrupt the search record: events tied to the earlier data can no longer be found under the new data. A conscientious check reconstructs both versions rather than settling for whichever was found first.

What secures identification

  • stable attributes instead of a name and a city
  • the intersection of several independent identifiers
  • the person in the negotiations matching the person in the documents
  • reconstruction of the record after a change of name or jurisdiction
Area 3 · Career

Biography, education and professional history

A biography in a CV is a selected version: the favourable episodes come first, the inconvenient ones are smoothed over or left out. A check does not look for something to catch a person on; it compares what is stated against independent traces. A position at a known company leaves traces in corporate documents, publications and professional references. Their absence proves nothing in itself, but a discrepancy between a loud claim and complete silence in the sources is a reason to ask a direct question.

Education and professional qualifications are verified where lawful mechanisms exist for this: official confirmations from educational institutions, public registers of professional bodies, licences and certifications. Here it is important to distinguish what can be verified from what cannot. The fact that a degree was awarded is officially confirmed in a number of jurisdictions; specific grades and circumstances, as a rule, are not. The check states plainly where the available confirmation ends.

More valuable than individual facts is the coherence of the record. A genuine career forms a sequence: roles develop, responsibility grows, transitions are explicable. A constructed biography often falls apart into inconsistencies: a position confirmed nowhere but in words; a period during which the person supposedly headed a major line of business yet left not a single trace; a sharp gap between the level claimed and the history observed.

The conclusion from this section is almost never binary. More often it is a map of confidence: part of the biography is confirmed by documents, part is consistent with indirect data, part is neither confirmed nor refuted. It is this map, rather than a label of "true or false", that is needed for a decision on a partnership.

What can be checked against sources

  • positions and roles from corporate documents and publications
  • education and qualifications through official confirmation mechanisms
  • the coherence of a career instead of isolated striking episodes
  • separating the confirmed, the indirect and the unavailable
Area 4 · Connections

Corporate connections, shareholdings and previous projects

In a business context a person is almost always connected with legal entities: as a shareholder, director, beneficial owner or signatory. In most European jurisdictions these connections are recorded in trade and corporate registers and are accessible through the interconnected company search system. It is here that the role claimed meets the role recorded in documents: "ran a business" becomes specific companies, dates, shareholdings and positions - or finds no confirmation.

Previous projects say no less than current ones. Companies in which a person was a shareholder or director leave a history: how they developed, how they ended, whether they were accompanied by bankruptcies, liquidations or disputes. A succession of companies with the same closing scenario is an observable pattern that is worth discussing before a partnership rather than after.

Connections between people and companies are reconstructed from a combination of indicators: overlapping directors, shared addresses, the sequence of corporate changes, public statements about the ownership of a business. All of this is data lawfully collected from open sources. But discipline in drawing conclusions matters here in particular: an observed connection is a connection, not proven control. The wording "the structure shows indications of a connection with such-and-such a person" and the wording "such-and-such a person controls this company" carry different weight and different consequences.

This difference is not caution for its own sake. A confirmed fact can form the basis of a claim or a contractual condition; a reasoned conclusion, the basis of a negotiating position; a hypothesis, only the basis for further checking. To conflate them is to take a decision resting on an assumption mistaken for a fact.

What corporate data reveals

  • confirmed roles, shareholdings and positions from registers
  • the history of previous companies and how they ended
  • related individuals and companies identified by a combination of indicators
  • separating a confirmed connection from presumed control

Граница вывода. Corporate registers confirm formal roles and connections. Actual control and informal arrangements are reconstructed from indirect data and remain an analytical conclusion.

A specialist's hands sorting through register extracts and a career chronology on a desk
The stated biography is verified against independent traces in sources rather than taken at face value.
Area 5 · Events

Court, regulatory and sanctions events

Significant events are the points at which a person has already faced a formal assessment: court proceedings, regulatory measures, inclusion in sanctions and restrictive lists. Unlike reputational publications, many such events are recorded in official sources and can be verified as at a specific date. EU sanctions measures, for example, are published officially and allow a subject to be checked against the current list rather than by hearsay.

Court involvement requires careful reading. A person may be a claimant, a defendant, a third party or a witness - the roles are fundamentally different. Involvement in a dispute in itself does not indicate bad faith: an active business almost inevitably gives rise to disagreements that reach the courts. What matters is the overall picture: the nature of the disputes, recurring patterns, the person's role, the outcome. A single dispute is an episode; a series of similar matters in which the person consistently appears in the same role is already a pattern.

Regulatory and sanctions events carry more weight than reputational ones: they rest on a decision by an authorised body. But they too are read in context. A name matching a listed subject is a reason for precise identification, not a ready conclusion: without confirmation that this is in fact the person being checked, the match remains a false positive.

The rule that runs through this whole section: an event is a fact, and its significance is a conclusion. The check records that the event occurred, establishes the role and the date, and separates what is confirmed from name coincidences. The assessment of the consequences for a particular partnership is made by the client together with a lawyer - on the basis of the fact, not in place of it.

What is checked against official sources

  • inclusion in current sanctions and restrictive lists
  • court involvement with the role and outcome established
  • regulatory measures by authorised bodies
  • precise identification to filter out name coincidences

Граница вывода. Official sources confirm that an event occurred and the person's role in it. They do not turn involvement in a dispute or a match against a list into proof of guilt - that requires a legal assessment.

Area 6 · PEP

PEP status without a presumption of guilt

PEP - a politically exposed person: someone who holds or has held a prominent public function, as well as their close family members and associates. International standards set out in the FATF recommendations require such persons to be treated with heightened attention - not because they are guilty, but because their position creates an increased risk of a conflict of interest and abuse of influence.

A key rule, and one often broken: PEP status is not an accusation and not a presumption of guilt. It indicates the need for a more thorough check, not a ready conclusion of bad faith. A great many politically exposed persons conduct their affairs entirely lawfully. Treating PEP status as a verdict is both a legal error and an injustice to the person.

In practice the status means specific rather than declarative steps: a more careful check of the source of funds and wealth, an assessment of how the public function intersects with the proposed partnership, attention to associates through whom influence is exercised more often than directly. The standards expressly extend the requirements to family members and close business associates.

For a decision on a partnership, what matters is not the label but the substance: whether the status is relevant to the matter, whether there is an actual conflict of interest, whether the wealth has a lawful explanation. The check answers these questions through facts and reasoned assessments, leaving the final decision to the client.

What PEP status means in practice

  • heightened attention, not an automatic refusal
  • a check of the source of funds and wealth
  • an assessment of how the public function and the partnership intersect
  • attention to close family members and associates
Area 7 · Reputation

Reputational material and verification of the original source

Public reputation is the most accessible and the least reliable layer. Publications, reviews and online mentions are found quickly, but their weight varies greatly: an investigation by a reputable publication and an anonymous post carry different value, although they appear side by side in search results. A reputation check is not a collection of mentions but work with their original source and reliability.

The first question about any negative material is where it came from. An identified author, verifiable facts, references to documents - that is one thing. An anonymous publication with no sources, appearing at a convenient moment, is another. Reputational material can also be an instrument of pressure: a conflict, an unscrupulous competitor or a former partner may be behind a campaign that looks like independent opinion. Distinguishing a genuine signal from organised noise is the main task at this layer.

The second question concerns completeness. The absence of negative material does not mean none exists: material may have been removed, pushed out of search results, or never published at all. Conversely, a single sharp review does not outweigh a consistent record. Reputation is read as a picture, not as a single line.

A conclusion on reputation is almost always framed as an assessment rather than a fact: "a consistent signal is observed, confirmed by several independent sources" or "the signal is isolated and the original source has not been established". Such wording is more honest and more useful for a decision than presenting the publications found as proven truth.

How reputation is read

  • establishing the original source and authorship of the material
  • separating an independent signal from organised pressure
  • assessing completeness rather than isolated striking mentions
  • framing the conclusion as an assessment, not as a fact
Area 8 · Flags

Red flags, limitations and questions to ask before entering a partnership

A red flag is not a verdict but a point that requires explanation. An experienced check distinguishes flags that almost always have a lawful explanation from those that add up to a troubling picture. In themselves, a change of jurisdiction, involvement in litigation, a complex ownership structure or PEP status are not evidence. What is troubling is not an individual fact but their combination and the person's reaction to a direct question.

The most significant signals almost always concern inconsistencies. A discrepancy between the role claimed and the documentary traces. A gap between the level of wealth and an explainable source of funds. A series of previous companies with the same ending. Persistent avoidance of simple clarifying questions. Taken separately, each point can be explained; together they change the distribution of risk.

Separate mention should be made of what a check does not establish, and of which it gives honest warning. It does not read a person's intentions and does not predict their future conduct. It does not replace legal characterisation: a finding of guilt, fraud or bad faith is made by a court, not by an analyst. It is limited by the availability of data: in some jurisdictions information is open, in others it is not, and the absence of a record does not equal the absence of a fact.

The practical outcome is a list of questions to put to the person before entering a partnership, not a ready verdict. A good check does not so much close the subject as turn vague unease into specific, concrete questions that it is appropriate to put to a prospective partner directly - and to assess not only the answers but also the willingness to give them.

What distinguishes a genuine flag from noise

  • a combination of signals rather than a single isolated fact
  • inconsistencies between what is claimed and what is observed
  • the person's reaction to direct clarifying questions
  • an honest statement of the limits of the available data

Граница вывода. Red flags indicate where to ask a question. They do not replace the person's own explanation or a legal assessment and are not evidence of a violation.

Practice

What a professional process looks like

The order of the areas is not accidental: each one builds on the previous, and the depth is determined by the significance of the decision, not by the habit of producing a "full package".

  1. 01

    Defining the task

    What kind of partnership is involved, what sums and roles, which jurisdictions, by what deadline a decision is needed, what is already known and from which source.

  2. 02

    Identification

    Precise establishment of identity by stable attributes, elimination of name matches, matching the person in the negotiations with the person in the documents.

  3. 03

    Career and education

    Checking the biography, positions and qualifications against registers, official confirmations and publications. Separating what is confirmed from what is unavailable.

  4. 04

    Connections and structure

    Corporate roles, shareholdings, previous projects and connected persons. Separating a confirmed connection from presumed control.

  5. 05

    Events and status

    Court, regulatory and sanctions events as at a given date, PEP status with verification of the source of funds. Elimination of false positives.

  6. 06

    Reputation

    Verification of the original source of publications, separation of signal from pressure, assessment of weight and completeness.

  7. 07

    Report and decision

    Fact, conclusion, hypothesis and the unknown - kept separate. A list of questions to put to the person and specific recommendations, rather than a "reliable / unreliable" label.

Result

What the client receives as a result

  • Confirmed identification of the person, suitable for further decisions: stable attributes, not a name match.
  • A map of career and education with an explicit separation: what is confirmed by a document, what is consistent with indirect data, and what remained unavailable.
  • A diagram of corporate connections and previous projects, distinguishing a confirmed connection from presumed control.
  • Verification of court, regulatory and sanctions events as at a given date rather than on the basis of rumour, with precise identification of the subject.
  • A balanced reputational assessment verified against primary sources, rather than a retelling of the publications found.
  • A list of specific questions to put to the prospective partner and a direct statement of what the check did not establish and why.
Limits

Limitations and the lawfulness of methods

A check on an individual is built on open and officially available sources: corporate and court registers, sanctions lists, official confirmations of qualifications, publications with verifiable authorship. It does not use unlawful access to closed databases, personal data, correspondence or banking secrecy, and it does not explain methods of obtaining such access.

Data availability differs by jurisdiction: in some countries corporate and beneficial ownership information is public, in others access is restricted or requires grounds. The absence of an entry in a particular register means that the data is not disclosed in that source, not that the fact does not exist. An honest check notes such limits rather than presenting the unavailable as verified.

A check does not provide a legal characterisation. A conclusion as to guilt, fraud, nominee status or bad faith is a matter for the court and a competent lawyer. The materials of a check may serve as a basis for their assessment but do not replace it. Any figures, timeframes and success rates are published only where documented.

A partner and an adviser comparing two versions of a professional biography at a desk

Composite example

A practical example

  1. Исходная ситуация: что выглядело убедительным

    An investor was considering entering a joint business with a person whose presentation looked convincing: many years of industry experience, senior roles at well-known companies, confident references.

  2. Первое расхождение: идентификация

    The discrepancy appeared at the identification layer. Some of the stated positions related to companies with a common name, and on stable attributes the connection to this particular person was confirmed for only part of the biography.

  3. Второе расхождение: карьера

    The second discrepancy was at the career layer. One of the key senior roles, presented as lasting several years, was not confirmed either in corporate documents or in industry publications for the relevant period.

  4. Третье расхождение: связи

    The third was at the connections layer. Several previous companies in which the person had been a participant ended in a similar way within a short period. This fact in itself did not prove bad faith.

  5. Как это было сформулировано в отчете

    None of the observations was framed as an accusation. In the report they were set out as discrepancies and questions requiring explanation, with a clear separation of what was confirmed, what was indirect and what was unavailable.

  6. Как изменились условия партнерства

    The decision was taken by the investor, not by the check. He asked direct questions. Some explanations were convincing, others were not. The partnership went ahead, but with a different structure: staged entry instead of a single injection, separation of powers and a right of exit if the risks were confirmed. The risk did not disappear - it became visible and manageable.

Граница вывода. A composite example based on typical matters; details have been changed. Пример показывает логику работы, а не результат конкретного клиента.

Preparation

What to prepare for the initial assessment

  • Precise details of the person: full name, the roles and companies known to you - taken from documents, not only from the presentation.
  • The substance of the prospective partnership: format, roles, amounts, signing authority, what exactly you are entrusting.
  • The jurisdictions connected with the person and the future business.
  • What you already know and from which source - so that you do not pay for work to be repeated.
  • The date by which a decision must be taken.
  • Specific doubts, if any: what exactly raises questions.

Documents, copies and personal data of third parties are not required at the first stage. The above is enough to assess the volume of work and the timeframe.

Questions

Frequently asked questions

  • Yes, within the limits of legitimate interest and using open sources. European regulation permits the processing of personal data without consent where it is necessary for a legitimate business interest and proportionate to it. A check is confined to business and risk factors and does not touch private life unrelated to the decision.

Conclusion

Conclusion

Checking a person before a partnership does not replace trust and does not pass judgment. It does something else: it turns the account a person gives of themselves into a map with clear boundaries - where what is stated is confirmed by a document, where it has been reconstructed from the body of data, and where it remained inaccessible.

The value of such a map lies not in compromising material found, but in an honest distribution of the unknown. You see where the decision on partnership rests on fact and where on assumption, and you receive specific questions that it is appropriate to put to a future partner before you tie your capital, reputation and common business to them. The risk does not disappear - it becomes visible, and therefore manageable.

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A hidden beneficial owner in an offshore structureCase

A hidden beneficial owner in an offshore structure

Reconstruction of actual control from the totality of open data, separating what is confirmed from what is assumed.

INITIAL ASSESSMENT

Need to check a person before a partnership or appointment?

Describe the situation, the roles and the jurisdictions in two or three sentences. We will tell you what can realistically be checked about the person, in what timeframe, and what will remain inaccessible. Documents and personal data of third parties are not required at the first stage.

Contact

An initial enquiry does not mean the matter is automatically accepted. After reviewing the request we will contact you through the channel you selected.