Process makes the genuine deal distinguishable.
Fraud indicators, the due diligence framework, governance, the transaction lifecycle — and what a completed transaction actually looks like.
Indicators are cumulative: one may have an innocent explanation; three do not.
- ×Below-market discounts with no coherent commercial rationale.
- ×Long broker chains; nobody has met the principal.
- ×Urgency engineering — "the allocation closes Friday."
- ×Shifting terms, jurisdictions, or named parties between drafts.
- ×"Crypto first / cash later" or other unsecured sequential demands.
- ×POF or wallet "proofs" that cannot be verified to source.
- ×Screenshots and videos in place of cryptographic proof.
- ×Documents with internal inconsistencies — fonts, dates, reference formats.
- ×Refusal of standard KYC, or recycled KYC packs seen in other deals.
- ×Unverifiable mandates "speaking for" unreachable principals.
- ×Free-mail addresses and messaging-app-only contact for "institutional" parties.
- ×Counterparty-nominated "escrow" or "attorneys" who resist independent verification.
- ×Settlement banks or custodians that change late in the process.
- ×Requests to move communication off recorded or documented channels.
- ×Names, entities, or wallets matching prior fraud reports or sanctions data.
Two or more confirmed indicators trigger enhanced diligence; any single disqualifying event — fabricated documents, sanctions match, impersonation — ends the engagement permanently and is recorded. Confirmed indicators feed the suspicious-activity procedure in BBC-DAM-2026-002 §20.
Diligence proceeds in gates. No gate is skipped, and commercial discussion does not advance past an unpassed gate.
Identity
KYC on all principals, UBOs, and intermediaries; sanctions and PEP screening; entity verification to registries.
Capacity
POF verified to source (buyer); wallet ownership plus live proof of coins (seller); authority documents for signers.
Provenance
Forensic screening of exact settlement wallets; source of funds and wealth evidenced; banking pre-clearance.
Structure
Settlement model agreed; professionals verified; contracts and instructions executed.
Approval
Compliance certification; risk rating assigned; transaction approved, conditioned, or declined in writing.
The instrument
The framework is operationalized through the Counterparty DDQ (BBC-DAM-2026-003): 53 questions across 21 sections, completed and certified by the counterparty, then independently verified. Completing it begins discussion; it does not conclude it.
Diligence depth scales with risk: transaction size, jurisdiction exposure, structure complexity, and relationship history move the requirement up — never below the Gate 1–5 floor.
Gate evidence is retained under the record-keeping requirements regardless of whether the transaction proceeds — declined engagements protect the next counterparty.
The desk
Transaction teams own counterparty conduct: gate discipline, documentation completeness, settlement execution, and escalation of indicators. No desk member may waive a control.
Compliance & risk
Independent review of every transaction file: KYC quality, screening results, structure approval, and risk rating. Holds unilateral veto. Maintains the fraud-indicator register and rejection log.
Legal & external
External counsel signs off on settlement structures and jurisdiction questions; periodic independent review of the framework itself, with findings reported to group management.
Compliance reviews blind.
Independent of the desk, indifferent to the commercial outcome, holding unilateral veto at every step. No relationship, no fee, and no time pressure outweighs the file. The scales are not a metaphor for balance between deal and control — the control side always carries the sword.
Iustitia, Bern · Image: Wikimedia Commons
Standing policies
The framework is deliberately conservative. BloomBridge Capital's commercial position is that lost transactions are recoverable; lost settlements are not. Counterparties who require speed over structure are referred elsewhere without prejudice.
Phase I — Qualify · Steps 1–2 run in parallel
Buyer file submitted
Complete KYC (entity, UBOs, signatories), proof of funds, banking details with bank awareness confirmed, and attorney details where the fiat leg settles via trust. The DDQ is completed and certified. Compliance opens the transaction record.
Seller file submitted
Complete KYC, wallet verification by signed message or micro-transfer on the exact settlement addresses, proof of coins in deliverable form, source-of-assets evidence, and receiving bank details. Initial forensic screening runs on all nominated wallets. Neither side discloses ahead of the other.
Phase II — Contract
Contracts executed
Transaction agreement with pricing formula (reference source and fix window), tranche schedule, settlement model, confirmation counts, default remedies, and dispute terms. NDAs and broker fee agreements completed; escrow or trust instructions signed by all parties.
Funds placed under settlement control
The fiat leg is funded into the agreed settlement control — attorney trust account, licensed escrow, or supervised banking arrangement. Crypto-side escrow is funded where the model requires it. No value is released at this step; positioning only.
Phase III — Clear
Compliance review
Full-file review: KYC completeness, sanctions re-screen, forensic re-screen of exact wallets, verification of professionals, and documentation integrity. Output is a written approval, conditioned approval, or decline. Approval here is the gate between positioning and execution.
Test transaction
A small tranche executes under the full settlement model — fiat micro-leg and crypto micro-leg through the identical rails, accounts, and addresses as the main transaction. Standard for all first transactions; waivable only in writing by risk management.
Phase IV — Settle & close
Main transaction executed
The main tranche is initiated per the agreed model — supervised DvP, escrow/trust release, or tranched build-up. Where a settlement call is used, all principals' professionals attend, the call is recorded, and each action is confirmed verbally and in writing.
Simultaneous settlement
Both legs release under the settlement control against objectively met conditions: fiat disburses against the agreed on-chain confirmation count; crypto releases against confirmed fiat receipt. At no point does one party hold both legs while the other holds neither.
Completion
Final confirmations exchanged: transaction hashes, bank credit advices, escrow and trust statements, settlement statements. The transaction record is completed and archived; post-settlement forensic spot-check run where directed.
Further tranches
For multi-tranche structures each tranche repeats steps 5–9 per the contracted schedule. Tranche sizes may escalate as settlement history accumulates; any change of party, wallet, bank, or structure suspends the schedule pending re-approval.
A first transaction between properly documented counterparties typically completes in days to a few weeks — dominated by verification and banking, not by the blockchain. Counterparties promising same-day first settlements are describing a different market, or none.
No step may be re-ordered to accommodate commercial pressure; the sequence is itself a control.
Objective release conditions, in writing, signed by all parties before value moves. In this market the documentation is not paperwork — it is the control.
Composite and anonymized for instruction; not a record of any specific transaction, and not a performance claim.
⊘ The counterfactual — where lookalike deals die
- G1"Seller's mandate" cannot connect the team to the principal — engagement ends. The most common single failure point.
- G2Wallet "proof" arrives as a screen-recording; signed message declined — engagement ends.
- G3Forensic screen shows material mixer exposure — declined and logged.
- G4Counterparty insists on "crypto first, cash within 48 hours" — declined under standing policy.
The completed transaction and the four failures followed the identical process. The process did not slow the genuine deal — it is what made the genuine deal distinguishable.
In this market, diligence is not the cost of the transaction. It is the transaction.