Trigger
Why was this case selected?
Registered country
Bulgaria
Review period
September 2026
Recent login distribution
More than 20 logins occurred outside the customer's registered country during the review period.
AI Investigation
What appears to have happened
Mock AI outputThe customer's account was opened several years ago with a Bulgarian registered address. Over the review period, the large majority of logins originated from Germany rather than Bulgaria, and this pattern appears consistent with recent months rather than a single trip. The customer's verified bank account and the majority of recent transactions are also German. The identity document on file is Bulgarian, and a previous reviewer accepted that same document as evidence of the customer's residential address. No proof-of-address document dated within the review period, or showing a German address, is recorded.
Key Evidence
Login Activity
Wallet Admin83 of 101 logins (82%) in the review period originated from Germany.
Payment & Funding
Payment InstrumentsThe verified funding account is a German bank account.
Transaction Activity
Core BankingTransactions in the review period are predominantly in euros with German merchant locations.
KYC
KYC SystemOriginal identity verification used a Bulgarian national identity document.
Address Verification
KYC SystemResidential address was accepted using the identity document rather than a separate proof of address.
Previous Reviews
Case ManagementOne prior review closed with no action; login geography was not a factor at that time.
Control / Policy Check
Prototype policy · synthetic example- Requirement
- Current residential address must be supported by qualifying recent proof of address.
- Observed
- A Bulgarian identity document was used as evidence for the customer's residential address.
- Additional context
- Recent behavioral evidence suggests that the customer may primarily reside in Germany.
- Potential discrepancy
- No recent German proof-of-address document is recorded.
Agent Conclusion
Mock AI outputPOTENTIAL CONTROL FAILURE
Login, payment, and transaction evidence consistently point to the customer's primary residence being in Germany, while the address on file relies on a Bulgarian identity document with no recent, independent proof of address. This is consistent with the residential address control not having been satisfied on an ongoing basis.
Recommended action
Request an up-to-date proof-of-address document from the customer and re-verify the registered address before further account activity is approved.
Evidence supporting conclusion
4 sources
Confidence
High
Human Review
The AI recommendation is a starting point, not the final decision. You own this decision.