Who Elucidate is, and how we fit alongside Mastercard.
View background introThe FI-assessment architecture deployed in MMCP staging and a sample EFI-scored report from the work already delivered under our existing MSA and SOWs.
Focus moves to payment-by-payment: validating each transaction in its own right.
View problem statementThe Commercial Payments offering: Elucidate's Payment Validation Agent that ingests RSP policy, pre-validates each payment, and attaches a routing recommendation, plus a proposed POC on historic corridor data.
A explainable risk score for FIs and transactions, combining static profile attributes with dynamic behavioural data.
Delivered as risk infrastructure that plugs into existing workflows.
Autonomous agents under bounded autonomy. Every decision logged with an explainable evidence trail.
This is not an introductory engagement, Elucidate has successfully collaborated with Mastercard on cross-border commercial payments for nearly two years.
Master Services Agreement executed with Mastercard procurement. No further commercial onboarding is required.
Two scoped engagements have been completed with Mastercard, including the sample EFI-scored report shown in the following section.
The Elucidate platform is integrated with the MMCP engineering team's staging environment. Connectivity and integration work has been completed.
The reference architecture currently deployed in MMCP staging.
Output produced in the previous engagement: a single financial institution scored end-to-end against the Elucidate FinCrime Index methodology. The same scoring engine and data spine underpin the product proposal that follows.
The bank appears to have a robust framework for managing financial crime risks, focusing on maintaining compliance with both national and international legislation across different sectors. It has implemented a variety of policies and initiatives to manage risks associated with sanctions, transactional activities, reputation, culture, bribery, and corruption, as well as its geographic footprint and customer portfolio.
Transactions are subject to rigorous assessments, with an emphasis on using environmental and social risk management systems. Additionally, the bank deploys systematic controls, particularly in dealings with high-risk countries, thus reflecting compliance with international standards to mitigate money laundering and the financing of terrorism.
No reported regulatory or legal scandals involving the bank were found within the last 36 months in the provided documents or context. The bank maintains a clean record concerning significant compliance issues or fines across its operations.
Every new originating bank requires bilateral negotiation with each RSP. Risk appetites are agreed pair-by-pair and do not propagate automatically.
High risk markets and nested flows, for example, demand case-by-case triage that does not scale operationally.
New flows, such as crypto provenance flows and the collections business with SME nesting, create renewed friction and misalignment.
Payments are bound to specific RSPs at the corridor level rather than routed dynamically, because no component reads each RSP's policy at run-time.
A single schema that feeds every upstream component, including transaction data, counterparty data, RSP policy statements, and dynamic behavioural signals, all normalised so the scoring engines and the agent layer operate on a consistent view.
A composite, explainable risk score per transaction and counterparty , combining static profile attributes (geography, sector, ownership, network) and dynamic behavioural data, in real time. The Elucidate FinCrime Index sits underneath as the institutional benchmark, with independent standing on both sides of any transaction.
Real-time pre-validation of every payment against the schema. The transaction arrives with a routing recommendation already attached, the evidence assembled across the underlying modules, and a drafted justification in every case.
When an RSP changes its appetite, routing recommendations update everywhere immediately, without each pair being renegotiated bilaterally.
Step through the current hard-tied path one hop at a time, then switch slides to see how the Payment Validation Agent intervenes — pre-validating against RSP appetite within the network and enabling a routing path that the current corridor mapping would not select.
The corridor's mapped RSP is the only available option. If its risk appetite does not match the payment, the flow is held or rejected — even where another RSP in the network would have accepted it.
The Payment Validation Agent evaluates each RSP's risk-appetite statement against the transaction's composite score and pre-validates the payment prior to settlement. The routing recommendation is delivered with the transaction, not as a downstream triage task.
The same payment routes through the same Mastercard rail to an RSP whose policy aligns with the transaction profile. When an RSP modifies its risk appetite, every routing recommendation across the network is updated in real time, eliminating the need for bilateral renegotiation.
This document accompanies the walkthrough requested in our recent discussion. The session will cover the material above against your actual RSP appetite logic, followed by scoping of the corridor to be used for the proof of concept.
Beyond per-payment validation, every institution in the network is scored across FinCrime, sanctions, governance and reputation dimensions — with high-risk signal counts and lending status tracked side by side, and thresholds set per segment.
| Institution | FinCrime Risk | Sanctions | Geographic Risk | Governance | Bribery & Corruption | Org. Reputation | High-Risk Signals | Lending |
|---|---|---|---|---|---|---|---|---|
| Bŭlgarska Fiktivna Banka | 67 | 15 | 63 | 67 | 89 | 89 | 12 | Y |
| Česká Banka Pro Testování a V… | 59 | 72 | 43 | 67 | 84 | 73 | 0 | Y |
| Magyar Teszt Bank | 49 | 15 | 42 | 47 | 79 | 85 | 0 | Y |
| CEE Union Transfer DEMO | 35 | 14 | 65 | 67 | 54 | 90 | 0 | Y |
| Bank Polski do Testów | 26 | 14 | 35 | 43 | 87 | 90 | 0 | Y |
| Hrvatska banka za Istraživanje | 25 | 14 | 65 | 67 | 71 | 40 | 0 | N |
| Dare-Parisian | 23 | 34 | 87 | 69 | 84 | 90 | 2 | Y |
| Instant Money Transfer Solutio… | 22 | 44 | 86 | 86 | 98 | 53 | 66 | Y |
Every regulatory action, sanctions development, and adverse-media event is captured as a discrete signal — categorised, linked to its source articles, and tracked to closure. Below: open signals on a single counterparty.
| # | Title | Status | Category | Articles | Created at |
|---|---|---|---|---|---|
| #919 | Türkiye Halk Bankası A.Ş. Money Laundering Investigation | Open | REG — Regulatory Action | 1 | 6/18/2026 |
| #921 | Dismissal of Halkbank Iran Sanctions Case by Federal Judge | Open | FOF — Former OFAC List | 1 | 6/18/2026 |
| #920 | Halkbank Iran Sanctions Case Concludes with No-Fine Deal | Open | FOF — Former OFAC List | 1 | 6/18/2026 |
| #897 | US Judge Grants Dismissal of Iran Sanctions Case Against Türkiye Halk Bankası | Open | FOF — Former OFAC List | 5 | 6/12/2026 |
| #911 | Sentencing of Key Witness in Halkbank Sanctions Evasion Case | Open | DEN — Denied Entity | 1 | 6/16/2026 |
| #896 | Halkbank Shares Surge as US Drops Iran Sanctions Case | Open | SEC — SEC Violations | 1 | 6/12/2026 |
| #899 | Dismissal of US Criminal Case Against Türkiye Halk Bankası A.Ş. | Open | REG — Regulatory Action | 3 | 6/12/2026 |
Provide a 12-month transaction file from one of the affected higher-risk corridors. Elucidate will analyse RSP risk appetites based on processed traffic, process the file through the Payment Validation Agent against an indicative appetite profile, and deliver a comparison against your current decisioning.
Cases where the agent produces the same decision and routes to the same RSP, with a drafted justification attached Establish a baseline alignment between the schema and your current decisioning.
Flows that an RSP with a compatible risk appetite could have accepted and flagging payments not currently reachable through the existing corridor mapping.
Payments rejected or escalated by the existing manual review queue that the agent would have cleared, accompanied by the supporting evidence trail.