What a finished file looks like.

Every file we review comes back as a folder a regulator can open without any Nikxius software. Below is a specimen built from one made-up customer: the minimum subset named in our pack specification, plus the frozen inventory the declarations bind to.

NXP-SPEC-0001 v1One finished file10 files, 7.3 KB

What is in the folder

  1. README.md02b68a214c96a01feaaf1850258c154dd33bbc965de90675bebf9ab8b3f8e500
  2. review.json3e39721c0b9c4ad26f01c798a0bca19a1c15bcaf0f49d5c68b27eec82721afe6
  3. sources/identity-extract.txtfa9341b187758e35a857cd468e7e6213377453557b015c562b9bd09ad68db3ad
  4. sources/screening-result.jsona8825a45693b6de6fbc5096d8ab6b4d60dedfa41b357b655cd0281c5523350f5
  5. sources/transaction-profile.csv0f59a88505c9247c2df92b45e2c369a435ab7cfae5751ab0aaaf42acd023b10e
  6. sources/index.json952cca473c864f2910e5e4c25b927afa5c72e937ce7fdc6c5870bb007edd4b74
  7. review-set.json1fa2a5285e8b8af0383c55d595acf4851e9b403454bfd76b72f9a8b830c03800
  8. attestations/reviewer.json5a96e1df9a85bf8370e2478613bf00676ac8762077889fe91ab522300fa57d76
  9. attestations/mlro.json682fae7517b9e63a1290c4ce3162f01b99c612dcc20ccf1155dadbeb5626fc47
  10. manifest.json5b696933cd4d7e134ad57e501d5e2ce24d3a3f828e10ce1033a6c6561cf11370

What was decided

Customer
SYN-00417
Trigger
Scheduled periodic review, 12 months (higher-risk segment under firm policy), 21 days overdue at intake
Risk rating
MEDIUM before, MEDIUM proposed
Declared
Money laundering reporting officer, 2026-10-08 14:02 UTC, unsigned specimen
Final
MEDIUM, accepted with one condition
Policy
KYC-PR-2026.2

What was checked

  1. CHK-01Identity re-verification of the legal entityPass
  2. CHK-02Ultimate beneficial owner confirmationNot completed
  3. CHK-03Sanctions and PEP screeningPass
  4. CHK-04Adverse mediaPass
  5. CHK-05Transaction profile against expected activityFinding
  6. CHK-06Source of funds refreshPass

What is still open

UNK-01 UBO register extract. Provider request SPEC-REQ-118 outstanding at review close. Next: Attach the extract and re-run CHK-02; a new release of this pack is then issued.

Receipt manifest 5b696933cd4d7e134ad57e501d5e2ce24d3a3f828e10ce1033a6c6561cf11370 ZIP 1ed20fdf4ed756990e7053e551aecbf58c39fa216a8efa41db8619fe1781f236

This is a specimen: a made-up customer, a made-up firm, made-up people. The file layout and the hashes are real; the hashes are computed from these exact files, so anyone can check that nothing changed.

How anyone can check it

  1. Each file in the folder has a fingerprint, a SHA-256 hash. Recompute the fingerprint of every file and compare it with the list in manifest.json. A missing file, an extra file or a different fingerprint means the folder is not the one that was signed off. Do not repair it; reject it.
  2. Open the two signed declarations, attestations/reviewer.json and attestations/mlro.json. Each carries the fingerprint of the frozen evidence list, so a signature cannot be moved to different evidence.
  3. The firm receives a receipt separately from the folder. Check that the receipt names this folder's manifest fingerprint.

Check it in this browser

This page can recompute every fingerprint from the published copy, or from files you unzipped yourself. The computation runs in your browser. Nothing is uploaded.

Select every file from the unzipped folder, including manifest.json.

Or on your own machine

sha256sum README.md review.json sources/* review-set.json attestations/*   # step 1: compare with manifest.json
sha256sum review-set.json                                                  # step 2: must appear in both attestations
sha256sum manifest.json                                                    # step 3: must match the receipt

On a Mac or Linux the command is shasum -a 256 or sha256sum; on Windows, Get-FileHash. A matching fingerprint shows the files are unchanged since sign-off. It does not show that the customer is safe, that the decision was right, or that a regulator will accept it.

The one page the MLRO signs

Everything the declaration binds to, on one sheet: the decision, the checks, what stayed open, who did what and when, and the fingerprints. A live sheet is what the firm's MLRO signs; this one is the specimen's.

NXP-SPEC-0001 v1

Periodic review sign-off

Customer
SYN-00417
Firm
Specimen EMI B.V. (fictitious)
Policy
KYC-PR-2026.2
Trigger
Scheduled periodic review, 12 months (higher-risk segment under firm policy)

Decision

Risk before
MEDIUM
Proposed
MEDIUM
Final
MEDIUM, accepted with one condition
Condition
Attach the extract and re-run CHK-02; a new release of this pack is then issued

Who did what

  1. Senior KYC analyst proposed
  2. Evidence frozen
  3. Second reviewer checked
  4. Money laundering reporting officer declared

Checks performed

CheckNameResult
CHK-01Identity re-verification of the legal entityPass
CHK-02Ultimate beneficial owner confirmationNot completed
CHK-03Sanctions and PEP screeningPass
CHK-04Adverse mediaPass
CHK-05Transaction profile against expected activityFinding
CHK-06Source of funds refreshPass

Open at close

UNK-01 UBO register extract. Provider request SPEC-REQ-118 outstanding at review close.

Integrity

Frozen evidence (review-set.json)
1fa2a5285e8b8af0383c55d595acf4851e9b403454bfd76b72f9a8b830c03800
Folder (manifest.json)
5b696933cd4d7e134ad57e501d5e2ce24d3a3f828e10ce1033a6c6561cf11370
Files in folder
10

Declaration

By signing, the MLRO declares the decision above on the evidence whose fingerprint appears under Integrity.

Name
Role
Signature
Date

Unsigned specimen. A live sheet carries the firm's agreed authentication and is issued with the folder it names.

What each part is for

Index
One list of everything in the folder, each item's fingerprint, size and who produced it.
The file record
Who the customer is (by reference), why the review happened, which version of the rules applied, the risk rating before and after, the decision, the reviewer, the second reviewer, the MLRO's sign-off, and the times.
Source documents
Copies of the documents the decision rested on, as they were at review time.
Checks performed
Each check with its result and, where a check could not be completed, why.
Integrity
Fingerprints for every item and one for the whole folder, so a change after sign-off is visible to anyone holding the original list.
Retention
How long we keep it is agreed per engagement. The firm always keeps its own copy.

What the folder does not claim

It records what was reviewed and decided. It does not claim that the customer is safe, that the decision was right, or that a regulator will accept it.

Evidence supports a decision. It does not make one. The firm's MLRO keeps the final say on every file. Nikxius is not a law firm, an auditor or a regulator. No folder promises a regulatory outcome. The service is looking for its first firms.

Open the specimen, then tell us what your folders would need to carry.

Thirty minutes on what the regulator asked for last time and what your files could not show.

Talk for 30 minutes

Nikxius is run by Nikhil Sood, who replies to every request personally.