TrustSmart

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For corporate and trust service providers

The Entity Obligation Index.

When a rule changes, which of your entities are caught, by when, and whose job. Cited, every line.

24 jurisdictions ~200 obligation cells One change-diff engine Request a walkthrough
Ch. I

Thursday afternoon

A regulatory change lands horizontally, across every entity you administer at once. Someone has to answer three questions: which of ours, by when, and whose job. In most licensed firms, that answer is still built by hand.

  1. 01Export the entity master.
  2. 02Filter by jurisdiction and legal form.
  3. 03Read the memo again.
  4. 04Argue the edge cases.
  5. 05Assign the re-determinations by hand.
  6. 06Hope nothing was missed.

Every firm calls it something different. Everyone recognises the afternoon.

Ch. II

The fine wall

The cost of getting it wrong is public, named, and priced. Each figure below is a published enforcement outcome against a licensed corporate or trust service provider.

  • CI$0 Intertrust Corporate Services, Cayman CIMA, 2022. AML failures the regulator described as a pervasive and protracted history of non-compliance.
  • £0 Utmost Worldwide The GFSC's largest discretionary penalty on record.
  • £0 Equiom Public enforcement notice.
  • £0 Artemis Trustees Public enforcement notice.
  • £0 Trident Trust Plus personal fines on three of its officers. In these centres, the compliance head is in the frame by name.
  • £0 Garfield Bennett Trust Negligent, significant and material contraventions, in the regulator's words.

Beneath the headlines, per-entity stacks compound. Cayman economic substance: CI$5,000 for a missed return, plus CI$500 a day. CI$10,000 for failing the substance test, CI$100,000 the year after, possible strike-off. Jersey: £10,000, then £100,000, then £50,000 per further failure.

The arithmetic is unkind. A 3,000-entity book with a one per cent process failure on a single obligation is thirty fines. The board asks whether you are exposed to the thing that firm was just fined for, and the honest answer is a week of manual work.

Ch. III

The join

Every tool this profession is offered stops one step short.

  • News feeds and horizon scanningStop at the alert. Every subscriber reads the same sentence.
  • Entity-management systemsTrack the deadlines a human already typed in.
  • Memos and retainersDescribe the change, not your book's exposure to it.

Nobody sells the join: change, times your book, times ownership.

TrustSmart computes what a change means for the entities you administer, with counts the data supports and a queue for the calls software should not make. Designed so the rule pack runs inside your environment and your entity book remains there. The packaged client-side runner is currently in build.

Ch. IV

One cell

Economic Substance · Cayman Islands Demo cell · illustrative

Supervisory attention Elevated · Trajectory Stable · named, cited drivers. No composite score, ever.

  • Pure equity holding companyIn scope · reduced test ES Act (2021 Revision), s.4
  • Investment fundOut of scope Excluded from "relevant entity", s.2
  • No relevant activity conductedNotification still files ESN due 31 January, in scope or not
  • Conducts a "relevant activity"?Determination required Fact-shaped test, routed to a named owner

Positions requiring your book

7

Determinations requiring a human

3

Grounded-only shipping · every line resolves to a pinpoint citation

A cell is one obligation regime in one jurisdiction, versioned and cited: the governing instrument, deadlines, the penalty stack, supervisory posture, and a scoping crosswalk from entity type to status.

Four statuses, and the last two carry the weight. Notification-or-claim-required, because nothing-to-determine still files. Determination-required, because whether an entity conducts a relevant activity is not knowable from any entity master. The product names the entities and the cited test, and routes the call to your people. It never makes it.

Model-inferred content does not ship in a report body. A tile with no published source says "not published by the regulator". Scarcity, displayed honestly, is information.

Scoping crosswalk, Cayman Islands Economic Substance cell: eight entity types across all four statuses, every row citing its provision, filing-still-due boxes on exempt rows, and two summary boxes: filings due despite scope (7) and rows the product will not decide (1)
The real thing, not the sketch: the Cayman Economic Substance crosswalk as shipped. All four statuses, every row cited to its provision, the filings that fall due despite scope collected under the table, and the rows the product will not decide listed beside them.
Determinations requiring a human (3): each item names the entity question, quotes the cited test to run, and says why no entity master can answer it
The determinations box from the same report: each fact-shaped call named, with the cited test a human runs. Queued for your people, never made.

Then the law changes.

Cayman Islands · s.2, definitions

International Tax Co-operation (Economic Substance) Act

Reconstructed change event · 2021 · illustrative rendering

"relevant entity" means

(a) a company, other than a domestic company, that is incorporated or registered under the Companies Act;

(aa) a partnership, other than a local partnership, that is formed or registered in the Islands;

(b) a limited liability company registered under the Limited Liability Companies Act;

Amendment in force 1 July 2021. Partnerships formed before that date: in scope from 1 January 2022.

This is the Thursday exercise. It ran while you scrolled.

TrustSmart · watching this cell

Change class · Definitional

A scope boundary moved. Stored classifications are outputs of the old rule, so they cannot be trusted to apply the new one. No confident re-scoping count will be produced from stale attributes. A work order issues instead.

Which is the question underneath: which of your classifications did this change just invalidate? Nothing else you run against a change answers that one.

Crosswalk delta

  • Exempted limited partnershipOut of scope→Determination required
  • General partnershipOut of scope→Determination required
  • Local partnershipOut of scope · unchanged

Work order · reconstructed demonstration

Rule text

Before and after, quoted and cited: s.2 definition of "relevant entity", as amended 2021.

Re-determination queue

412 partnerships of a 3,000-entity book, each against the cited relevant-activity test.

Owner

Head of Compliance, Cayman office.

Deadline

Before the first ESN cycle closes, 31 January.

Synthetic book · illustrative · no client data

That page exists. Here it is.

The act above is a reconstruction. This is the page it reconstructs, captured from the product as it runs: one definitional change under the Private Funds Act 2020, a 250-entity synthetic book, 128 entities addressed, and every one of them in exactly one queue, with an owner and a deadline.

The change-event work order page, full length: the synthetic-book banner, the event header with rule-pack hashes and 128-of-250 chips, three definitional changes with before-and-after rule text and no entity counts, one mechanical change automated end to end, and the book split into five queues with owners and deadlines
The work order, full length: definitional changes carrying quoted before-and-after rule text and deliberately no entity counts, the one mechanical change automated end to end, and the book split into queues: 11 to notify, 21 to register, 26 auto-re-scoped, 70 routed to a human with the cited test attached. The banner at the top says what the data is: a synthetic book, no client data.
Ch. VI

How it is built

Two columns, two tenses, and nothing between them. The left column runs today and produced the cells you can read. The right column is roadmap, written in the future tense for exactly that reason. A line moves left only when you can watch it run.

Runs today
  1. 01Extraction is confined to a 45-domain primary-source whitelist. Legislation portals, gazettes, regulators, registries, tax authorities, standard-setters. Law-firm briefings are excluded by design, because the standard is the instrument itself.
  2. 02An adversarial second pass re-checks every substantive claim and returns one of four verdicts: Confirmed, Adjusted, Refuted, Unverifiable. On the Cayman cell: 21 findings, 21 confirmed, each taken to the primary text.
  3. 03Corrections are written into the fields they correct, derived values recomputed, the document re-validated. Fact-checking is a closed step, not a reporting one.
  4. 04Confidence is computed from citation coverage, never asserted by the model that wrote the text.
  5. 05A ship gate blocks the export on an unapplied correction, an unresolved citation, a disputed fact, an ungrounded section or a rule pack that disagrees with the body; an evidenced absence (a named register searched, nothing found) ships disclosed rather than blocked.
  6. 06Disagreements go to a human, and the decision is recorded in the cell’s ledger. A correction offered without a quoted provision stays disputed.
  7. 07No model runs when you read a cell. Scoping is a pure function over a versioned, content-hashed rule pack with citations carried inline. Same pack, same book, same answer, today and in two years.
  8. 08The board-pack regulatory-change section generates from the covered cells: bands, version ledgers, classified changes, work orders and both honesty counts, assembled into a minutable board paper. Cells outside the gate are listed on it, never hidden.
On the roadmap
  1. ·Continuous watch loops will run over each cell’s monitored sources. Every cell already carries the list of sources it depends on. Nothing watches them on a schedule yet: today a refresh is initiated, not triggered.
  2. ·Multi-model consensus will move onto cells from the sibling product, where it runs now: figures locked deterministically, only the prose rewritten, then re-validated against the locked figures.
  3. ·Prompts will be refined per jurisdiction from the adjudication record: what a human corrected, and where, becomes the signal for the next generation of that cell.

The roadmap column is the part a vendor is tempted to blur. Keeping the tenses apart is cheaper than being caught having merged them.

Sources and Citations panel on the Cayman cell: 11 of 12 sources on whitelisted official hosts, 0 of 11 linked URLs reaching a section pinpoint, resolution checks dated 2026-08-27, one badge review flag, shared-page flags shown per source
Steps 01 and 04, on screen: the Cayman cell’s sources, 11 of 12 on whitelisted official hosts, each resolution checked and dated, the twelfth shown as label-only. The limits are flagged on the panel itself: shared-page pinpoints are disclosed rather than dressed up as deep links, and where the model over-claimed a badge, the computed badge is the one displayed.
Verification panel on the BVI UBO cell: 8 claims checked on 2026-08-27, 7 confirmed, 0 adjusted, 0 refuted, 1 unverifiable, 1 demoted as label-only, with a later regrounding pass recorded
Steps 02 and 06, on screen: the verification panel on the BVI UBO cell, 8 claims checked under four verdicts, label-only confirmations taken back to the primary text by a regrounding pass and one demoted where it could not be, and the unverifiable claim disclosed, not averaged away.
Ch. VII

The ledger

Every cell carries a version and refresh ledger. It is a documented regulatory-change process, generated as a side effect of using the index: the thing a supervisor asks a firm to demonstrate, demonstrated.

Law as at
25 August 2026
Guidance version
v4.1 (demo cell, illustrative)
Last regime event
1 July 2021 · partnerships brought into scope
Next known date
31 January · annual ESN cycle

Everything the product emits is written to be read twice: once by you, once by your regulator. No composite scores. No breach findings about a client entity, and no assurances either. Fact-shaped calls are queued for your people, never made for them.

Regulatory monitoring and scoping support. Not legal advice, not a compliance determination, not a filing.

TrustSmart is in private preview with corporate and trust service providers. Request a walkthrough.