FinTech UK Trade Finance Platform -- Receivables Discounting

Invoice verification

detecting fraudulent invoices is the primary credit risk in trade finance.

Digital verification

• 1HMRC MTD VAT API (supplier submits VAT invoices -- verify invoice exists in HMRC VAT records),
• 2Companies House API (verify supplier and buyer are registered UK companies -- officer search, filing history, SIC code),
• 3bank statement analysis (Open Banking -- TrueLayer AISP -- verify customer receives payments from declared buyer),
• 4Companies House credit check (company age, filing timeliness -- early warning of financial distress),
• 5HMRC PAYE data (via HMRC API -- employee headcount verification for SME fraud detection).

HMRC MTD VAT invoice match

84% of UK SME invoices verifiable via HMRC MTD -- reduces manual fraud investigation by 84%.

Trade finance credit assessment

• 1buyer credit (buyer pays the invoice -- buyer credit quality is primary risk),
• 2supplier credit (supplier may issue fraudulent invoices or go insolvent -- secondary risk),
• 3concentration risk (single buyer > 25% of facility -- diversification requirement),
• 4industry risk (certain SIC codes excluded from facility),
• 5invoice verification score (HMRC MTD match + Companies House + Open Banking -- automated risk score).

ML credit model

XGBoost -- trained on UK SME payment data.

AML screening

• 1buyer and supplier screened against sanctions (ComplyAdvantage API),
• 2PEP screening (politically exposed persons in company ownership),
• 3UBO (Ultimate Beneficial Owner) verification (Companies House PSC data). FCA COBS regulated credit -- affordability assessment documented.

Trade finance funding

• 1facility approved (credit limit set for customer),
• 2invoice submitted (customer submits invoice for discounting),
• 3pre-payment (ClickMasters platform pays supplier 85% of invoice value on verification),
• 4customer repayment (buyer pays invoice -- repayment deducted from facility),
• 5final settlement (remaining 15% less discount fee paid to customer on buyer payment).

GoCardless VRP

recurring variable payments for trade finance repayments (buyer payment variable in amount and timing -- VRP ideal).

FCA PS21/3 IBS

payment initiation to supplier is an IBS -- Impact Tolerance designed for payment initiation (4-hour maximum downtime).

AML MLRs 2017 for trade finance

• 1KYC at onboarding (Onfido identity verification for SME directors, ComplyAdvantage sanctions screening),
• 2enhanced due diligence (EDD) for high-risk customers (high-risk countries, cash-intensive SIC codes),
• 3transaction monitoring (unusual invoice patterns -- same buyer every month at exactly the same amount = potential circular trade fraud),
• 4SAR filing (NCA goAML -- Suspicious Activity Report within 24 hours of decision to file),
• 5record retention (MLRs 5-year -- customer due diligence records and transaction history).

Trade finance AML

circular trade fraud (company A invoices company B, company B invoices company A, both access credit) is the primary AML typology.

ClickMasters AML model

network analysis on company relationships -- circular trade pattern detection.