Conduct comprehensive related-party relationship investigation and related-party transaction identification for corporate customers to prevent related risks from being transmitted to the credit subject. The investigation must run through the entire pre-loan, in-loan, and post-loan process.
Target Role
- Role: Credit approver, risk manager, corporate relationship manager, compliance review officer
- Use Cases: Pre-loan related-party investigation (first credit extension to a new customer), in-loan related-party transaction monitoring (duration monitoring), in-depth investigation when post-loan risk warnings are triggered, special assessment for large credit extensions/group customer credit extensions
- Output Purpose: Generate a structured related-party graph and related risk report for reference in credit approval decisions, risk pricing adjustments, and guarantee scheme design
- Decision Level: High risk (R1-R6 triggered) must be reported to the compliance department and risk management department; medium risk requires additional guarantees or reduced limits; low risk is included in routine post-loan monitoring
- Execution Frequency: Mandatory for the first credit extension to a new customer, reviewed every six months for existing customers, and ad hoc investigation when equity changes/senior management changes/risk warnings are triggered
Data Sources
Required Data
| Data Item | Source | Acquisition Method | Sensitivity Level |
|---|---|---|---|
| Customer Basic Information | ECIF system, business registration data interface | API call/file import | Internal |
| Equity Penetration Chart | Tianyancha/Qichacha API, business registration system | API call | Public |
| Credit Report Related Information | People's Bank of China credit reporting system | Credit inquiry interface (authorization required) | Sensitive |
| Corporate Financial Statements and Transaction Records | Credit system, core banking system | Database query/file import | Internal |
| Regulatory Documents and Related-Party Determination Standards | Knowledge base/references/ | File reference | Public |
Data Masking Rules
- Sensitive information such as customer names, ID numbers, and bank account numbers must use placeholders in reports and logs (e.g.,
[客户名称]、[证件号码]) - Credit inquiries must obtain the customer's written authorization; inquiries may not be made without authorization
Degradation Strategy
- Equity penetration API unavailable: Use the most recently cached equity penetration chart, noting "data is not real-time, manual verification recommended"
- Credit reporting system unavailable: Conduct a preliminary investigation based on the financial statements and guarantee contracts provided by the customer, noting "credit reporting data is missing, investigation results may be incomplete"
- Transaction records unavailable: Estimate the proportion of related-party transactions based on the tax returns and financial statements provided by the customer, and note "transaction records missing, related-party transaction identification may be incomplete"
- Business registration data unavailable: Use the business license and articles of association provided by the customer to screen for equity relationships, and note "business registration data missing, hidden relationships may be omitted"
Constraints
Regulatory basis: Guidelines on Risk Management of Credit Business to Group Customers of Commercial Banks (Yin Jian Fa [2010] No. 92) — concentration of credit extension to group customers and related parties Measures for the Administration of Large Exposures of Commercial Banks (Order of the China Banking and Insurance Regulatory Commission No. 1 of 2018) — exposure limits for related customers Accounting Standard for Business Enterprises No. 36 — Disclosure of Related Parties — standards for identifying related parties Bank's internal administrative measures for related-party transactions — specific screening standards and reporting requirements
- Pierce through to natural persons: Equity relationships must be pierced through to the ultimate natural-person actual controller and must not stop at intermediate legal persons
- Full-dimensional coverage: All six types of related-party relationships (equity/management/family/transaction/guarantee/hidden) must be screened, and none may be selectively ignored
- Hidden relationships must be checked: Hidden relationship signals such as the same registered address, contact telephone number, and finance personnel must be separately noted
- Four-flow consistency verification: Identification of related-party transactions must be cross-verified through the contract flow, invoice flow, logistics/service flow, and fund flow, and may not be judged authentic based on matching of only two flows
- Dynamic update: When related-party information changes (equity changes, changes in senior management, newly established enterprises), the screening results must be updated promptly
- Unauthorized action prohibited: This skill only provides related-risk screening results and must not directly make credit approval decisions
- Mandatory enforcement of red lines: If any veto condition (R1-R6) is triggered, it must immediately be marked in red at the top of the report and must not be ignored because of a "good customer relationship"
Execution steps
Execute in the following four-step order, output intermediate results at each step, and finally summarize to generate a complete report.
Step 1: Related-party identification
Comprehensively identify enterprise related parties from six dimensions and form a related-party list. Integration tip: map to your bank's customer information system (ECIF), equity penetration query interface, business registration data interface, credit report related-party information, or equivalent data aggregation tools
1.1 Equity relationships
| Identification standard | Penetration depth | Data verification |
|---|---|---|
| Legal persons/natural persons with direct shareholding ≥ 20% | Direct layer | Business registration information |
| Indirect shareholding ≥ 20% (through multiple equity layers) | Pierce through to the ultimate beneficiary | Equity penetration tool |
| Persons acting in concert (presumed based on agreements/kinship relationships) | Presumption layer | Public information + inference from transaction behavior |
| Determination of actual controller: shareholding ≥ 50% or actual control of the board of directors | Pierce through to natural persons | Business registration + articles of association |
Key execution points：
- Pierce through equity for at least 3 layers; cross-shareholding and circular shareholding found must be noted
- Concealed control relationships such as VIE structures and nominee holding agreements must be listed separately
- Persons acting in concert should be assessed not only by agreements but also by transaction behavior (such as synchronized increases/decreases in holdings and synchronized voting)
1.2 Management relationships
| Identification scope | Affiliation determination | Verification method |
|---|---|---|
| Other enterprises where the legal representative holds a position | The same natural person serves as legal representative | Business registration executive position query |
| Other positions held by directors, supervisors, and senior executives | Other enterprises where they serve as director/supervisor/senior executive | Business registration executive position query |
| Cross-holding of positions by key financial personnel | The financial officer and cashier hold positions in multiple enterprises within the same actual controller system | Enterprise annual reports/on-site visits |
1.3 Family affiliations
| Scope of relationships | Determination of affiliated enterprises | Look-through standards |
|---|---|---|
| Enterprises controlled by the actual controller's spouse | The spouse is the legal representative or holds ≥ 20% equity | Look through to spouse |
| Enterprises controlled by the actual controller's parents or children | Controlled by immediate family members | Look through to immediate family members |
| Enterprises controlled by collateral blood relatives within three generations of the actual controller | Siblings, grandparents/maternal grandparents, grandchildren/maternal grandchildren | Relationship graph inference |
Execution points：
- Family affiliations must be inferred based on public information; when they cannot be fully confirmed, mark "presumed affiliation, recommend the client provide supplementary explanation"
- Pay attention to "shell company" characteristics: no actual operations, registered address is a residence, no employee social insurance, frequent fund transactions with the borrowing enterprise
1.4 Transaction affiliations
| Identification criteria | Threshold | Data source |
|---|---|---|
| Sales proportion to a single customer | ≥ 30% of annual revenue | Enterprise financial statements/tax returns |
| Procurement proportion from a single supplier | ≥ 30% of annual procurement amount | Enterprise financial statements/tax returns |
| Concentration of top five customers/suppliers | Total ≥ 70% | Enterprise financial statements |
Execution points：
- The list of top five customers/suppliers must be cross-checked against the list of affiliated parties, and any overlap must be marked
- For enterprises with high transaction concentration, the risk of dependence on a single customer must be assessed
1.5 Guarantee affiliations
| Type | Definition | Risk characteristics |
|---|---|---|
| Mutual guarantee | A guarantees B, and B guarantees A | Two-way risk transmission |
| Joint guarantee | Multiple enterprises mutually guarantee each other, forming a guarantee circle | Chain risk transmission |
| Circular guarantee | A→B→C→A forms a closed loop | Closed-loop risk amplification |
| Hidden guarantee | Actual guarantee commitments not registered in the credit report | Underestimation of contingent liabilities |
Execution points：
- Extract external guarantee information from the credit report and cross-check it against the list of affiliated parties
- If a guarantee circle exceeds 5 enterprises, mark "large guarantee circle risk"
- Hidden guarantees are verified through the "contingent liabilities" notes in enterprise financial statements and on-site visits
1.6 Hidden affiliations
| Signal | Identification method | Risk implication |
|---|---|---|
| Same registered address | Business registration address comparison | May be controlled by the same actual controller |
| Same contact phone/email | Business registration information comparison | Sharing administrative resources, there is a connection |
| Same finance personnel | Annual report disclosure/on-site visit | Integrated financial management |
| Same audit firm + signing accountant | Audit report comparison | May uniformly coordinate financial data |
| Synchronized business registration changes | Change timing and content are highly consistent | Signal of coordinated action |
Step 2: Identification of Abnormal Characteristics of Related-Party Transactions
Based on the list of related parties, analyze the abnormal characteristics of related-party transactions.
| Abnormal characteristic | Identification criteria | Data verification | Risk level |
|---|---|---|---|
| Funds idling | Frequent large transfers between related enterprises (more than 3 per month on average or more than 5 million in a single month), with no genuine trade background (no corresponding contracts/invoices/logistics) | Bank statements + cross-check with contracts and invoices | 🔴 High |
| Transfer pricing | Related-party transaction prices deviate from market prices by ≥ 20% (procurement prices too high/sales prices too low, or vice versa) | Comparison of related-party transaction contracts vs non-related-party transaction prices | 🔴 High |
| Fictitious transactions | Related-party transactions have only contracts/invoices, with no corresponding logistics/fund flows; or logistics do not match the transaction direction | Four-dimensional cross-check of contracts + invoices + logistics documents + bank statements | 🔴 High |
| Profit transfer | The borrower's gross margin/net margin is significantly lower than that of non-related-party transactions; or profits mainly flow to related parties | Analysis of segment income statements of related-party transactions | 🟡 Medium-high |
| Guarantee chain risk | Mutual/cross guarantees involve ≥ 3 enterprises, or total guarantees > 50% of net assets | Credit guarantee information + business registration equity penetration | 🟡 Medium-high |
| Fund misappropriation | Related-party accounts receivable/other receivables account for > 30% of current assets, and the aging is > 1 year | Balance sheet + aging analysis | 🟡 Medium |
| Horizontal competition | Related parties engage in the same business as the borrowing enterprise, with competition for customer/supplier resources | Business registration scope + on-site visit | 🟢 Low (watch) |
Key execution points：
- When identifying related-party transactions, the "four flows in one" verification must be performed: contract flow, invoice flow, logistics/service flow, and fund flow must match each other
- If only two flows match (such as contract + invoice) but there is no corresponding logistics/fund flow, mark as "suspected fictitious transaction"
- Related-party transaction ratio = related-party transaction amount / total amount of similar transactions, and must be calculated by item (procurement/sales/borrowing/guarantee)
Step 3: Related-Party Risk Assessment
Based on the related-party information and transaction characteristics, assess the impact of related-party risk on credit safety.
3.1 Credit concentration risk
| Assessment indicator | Threshold | Handling if exceeded |
|---|---|---|
| Single-customer credit concentration | ≤ 15% of net Tier 1 capital | If exceeded, must reduce exposure or report to head office |
| Group customer credit concentration | ≤ 20% of net Tier 1 capital | If exceeded, must reduce exposure or report to head office |
| Total credit ratio of related customers | Comprehensive judgment based on industry characteristics and customer qualifications | If ratio > 50%, a special explanation is required |
3.2 Operating Independence Assessment
| Assessment Dimension | Independence Standard | Dependence Signal |
|---|---|---|
| Procurement independence | Related-party transaction procurement ratio < 30% | ≥ 30% mark as dependence risk |
| Sales independence | Related-party transaction sales ratio < 30% | ≥ 30% mark as dependence risk |
| Fund independence | No fund occupation, no mandatory cash pooling | Presence of cash pool/cash pooling marked |
| Personnel independence | No cross-holding of positions by senior management/finance | Cross-holding of positions marked |
3.3 Guarantee Chain Risk Assessment
| Assessment Indicator | Risk Threshold | Assessment Conclusion |
|---|---|---|
| Number of enterprises in the guarantee circle | ≥ 3 | Guarantee circle formed |
| Number of enterprises in the guarantee circle | ≥ 5 | Large guarantee circle, high risk |
| Length of guarantee chain | ≥ 3 levels (A→B→C) | Long risk transmission chain |
| Total external guarantees/net assets | > 50% | Excessive guarantees |
| Total external guarantees/net assets | > 100% | Triggers one-vote veto R5 |
3.4 Overall Financial Health of Related Enterprises
- Summarize the debt-to-asset ratio, current ratio, and net profit trend of related enterprises (including the borrowing enterprise)
- If the overall debt-to-asset ratio of related enterprises > 70% or the overall net profit is negative → mark "financial weakening of the related group"
- Watch for "robbing Peter to pay Paul" signals: frequent short-term fund lending between related enterprises
Step 4: Report Output and Disposal Recommendations
Summarize the results of the first three steps and output a structured related-party map and risk report.
4.1 Related-Party Map
[借款企业]
├── 股权关联
│ ├── [股东A] 持股 XX%
│ └── [股东B] 持股 XX%
├── 管理层关联
│ └── [法人] 兼任 [企业C] 法人
├── 家族关联
│ └── [实控人配偶] 控制 [企业D]
├── 交易关联
│ └── [客户E] 销售占比 XX%
├── 担保关联
│ └── [企业F] 互保，担保金额 XX 万
└── 隐性关联
└── [企业G] 同地址/同电话
4.2 Risk Classification
| Risk Level | Determination Criteria | Disposal Recommendation |
|---|---|---|
| 🔴 High risk | Suspected idle fund circulation/fictitious transactions; or total guarantees > 100% of net assets; or related-party transaction ratio > 50% | Recommend suspending credit and reporting to the compliance department |
| 🟡 Medium risk | Related-party transaction ratio 30%-50%; or guarantee circle of 3-5 enterprises; or signs of profit transfer | Recommend adding guarantees, reducing limits, and strengthening monitoring |
| 🟢 Low risk | Related-party transaction ratio < 30%; no abnormal characteristics; short guarantee chain | Normal credit, included in routine post-loan monitoring |
4.3 Disposal Recommendation Template
| Finding Type | Disposal Requirement |
|---|---|
| Related-party transaction ratio > 50% | Explain in a separate section of the credit report, and recommend adding independent guarantees |
| Suspicion of fund idling or fictitious transactions | Report immediately to the compliance department; recommend suspending credit and initiating a special investigation |
| Circular guarantees/large guarantee circle | Recommend reducing mutual guarantee limits and introducing external independent guarantees as a substitute |
| Undisclosed hidden related parties | Require the customer to supplement disclosure, and update the related-party map after verification |
| Customer refuses to cooperate with the investigation | Explicitly note in the report; recommend prudent handling or higher risk pricing |
Veto conditions (related-party transaction level)
If any of the following conditions is triggered, it must be immediately marked in red at the top of the report, and credit should be suspended and reported.
| No. | Trigger condition |
|---|---|
| R1 | Clear evidence is found of fund idling or fictitious related-party transactions to obtain credit funds |
| R2 | Related-party transaction pricing deviates severely from market price (≥ 30%), and no reasonable commercial explanation can be provided |
| R3 | The borrowing enterprise systematically transfers core assets/profits to related parties through related-party transactions, showing signs of tunneling |
| R4 | Related-party guarantees form a circular guarantee circle (closed loop ≥ 3 companies), and any enterprise in the circle already shows risk signals |
| R5 | Total external guarantees > 100% of net assets, indicating excessive guarantee risk |
| R6 | The enterprise or actual controller intentionally conceals major related-party information, confirmed true through multi-source cross-verification |
Quality requirements
- Penetration depth meets the standard: Equity relationships must be penetrated to the ultimate natural person, with at least 3 layers of penetration
- Full coverage of six dimensions: All six types of relationships must be investigated: equity/management/family/transaction/guarantee/hidden
- Four-flow-in-one verification: Identification of related-party transactions must be cross-verified through contract flow, invoice flow, logistics/service flow, and fund flow
- Veto conditions prioritized: R1-R6 must be checked first in step 2, and marked once triggered
- Quantification first: Specific values must be provided for related-party transaction proportion, price deviation, guarantee concentration, etc.
- Do not omit hidden relationships: Hidden signals such as the same address/phone/financial personnel must be listed separately
- Dynamic update mechanism: Related-party information must be updated promptly when it changes, and the report must indicate the data timestamp
- Customer cooperation record: If the customer refuses to cooperate with the investigation, it must be explicitly recorded and prudent recommendations must be given
Audit Trail
Execution of this skill must record an audit log in the following JSON format:
{
"skill_name": "credit-related-party-detection",
"execution_time": "2026-05-05T14:00:00+08:00",
"operator": "[操作用户]",
"customer_name": "[客户名称]",
"business_scenario": "贷前排查/贷中监控/贷后预警",
"steps": [
{"step": "步骤0:数据确认与验证", "result": "通过/失败", "duration_seconds": 5},
{"step": "步骤1:关联方识别", "related_parties_count": 15, "result": "通过"},
{"step": "步骤2:异常特征识别", "abnormal_features": ["资金空转"], "rejection_triggered": "R1", "result": "红色警示"},
{"step": "步骤3:风险评估", "risk_level": "高风险", "result": "通过"},
{"step": "步骤4:报告输出", "report_id": "RP-2026-001", "result": "完成"}
],
"data_sources_used": ["ECIF系统", "天眼查API", "征信系统", "信贷系统"],
"degradation_applied": ["征信系统不可用,使用客户提供的财报"],
"rejection_flags": ["R1"],
"report_generated": true
}
Audit log retention period: At least 3 years.
Gotchas
#1: Equity penetration stops at an intermediate-level legal person
- Symptom: The related-party list only shows direct shareholders (corporate entities), without penetrating to the ultimate natural-person actual controller.
- Cause: The equity penetration API only returns first-tier shareholders, or the AI does not recursively query multi-layer equity during execution.
- Solution: Must recursively penetrate to the ultimate natural person; if a VIE structure or nominee holding agreement is found, it must be listed separately and marked as a "hidden control relationship".
#2: Hidden related-party signals are ignored
- Symptom: The report does not mark hidden related parties sharing the same registered address, contact phone number, or financial personnel.
- Cause: Relies only on equity penetration and executive tenure queries, without performing industrial and commercial registration information comparison.
- Solution: Must perform the six-signal hidden affiliation check (same address/same phone/same email/same finance personnel/same audit firm/synchronized changes); if any signal is found, it must be flagged separately.
#3: Incomplete four-flow unification verification
- Symptom: Determines that a related-party transaction is genuine based only on matching the "contract + invoice" two flows, without checking logistics and capital flows.
- Cause: Transaction flow data is missing or the AI skips logistics/capital flow verification during execution.
- Solution: Must perform four-flow unification verification; if only two flows match, mark it as "suspected fictitious transaction" and must not directly determine it to be genuine.
#4: Circular guarantee circle not identified
- Symptom: Guarantee relationships list only direct mutual guarantees and do not identify the circular guarantee closed loop A→B→C→A.
- Cause: Recursive tracing of the guarantee chain was not performed, or the count of enterprises in the guarantee circle is incorrect.
- Solution: Must extract external guarantee information from the credit report, perform recursive tracing of the guarantee chain, and mark "circular guarantee circle risk" when a closed loop of ≥3 companies is found.
Examples
Example 1: Pre-loan affiliation investigation (first credit extension for a new customer)
User input:
请对XX制造有限公司进行贷前关联排查,统一信用代码:91110000MA001XXXX,申请授信金额5000万元。
Skill execution process:
- Step 0: Verify that the customer name and unified credit code are complete, and confirm that the investigation time point is "pre-loan investigation"
- Step 1: Six-dimensional related-party identification → found 15 related parties (5 equity-related, 3 management-related, 2 family-related, 2 transaction-related, 2 guarantee-related, 1 hidden affiliation)
- Step 2: Abnormal feature identification → found "related-party transaction sales proportion 35%" (medium risk), "guarantee circle enterprises 4" (medium risk), no R1-R6 trigger
- Step 3: Risk assessment → operational independence assessment (insufficient sales independence), guarantee chain risk assessment (medium-sized guarantee circle), comprehensive determination of medium risk
- Step 4: Output report → related-party map (tree structure) + risk grading (medium risk) + disposal recommendations (add independent guarantees, strengthen post-loan monitoring)
Output key points:
- Core conclusion: Found 15 related parties, related-party transaction sales proportion 35%, guarantee circle 4 enterprises, comprehensive determination of medium risk
- Key risks: Insufficient sales independence, medium-sized guarantee circle
- Disposal recommendations: Add independent guarantees to replace mutual guarantees, strengthen post-loan related-party transaction monitoring
Example 2: Post-loan risk warning triggered (suspected capital circulation without real trade background discovered)
User input:
XX集团贷后预警触发,发现与3家关联企业频繁资金往来,请深度排查关联风险。
Skill execution process:
- Step 0: Verify that customer information is complete, and confirm that the investigation time point is "post-loan warning"
- Step 1: Six-dimensional related-party identification → found 22 related parties (including 3 warning enterprises)
- Step 2: Abnormal feature identification → found "capital circulation without real trade background" (average 8 transfers per month, single maximum 8 million, no real trade background), triggering R1 one-vote veto
- Step 3: Risk assessment → weakened finances of the related-party group (overall asset-liability ratio 75%), credit concentration exceeds the limit
- Step 4: Output report → red warning R1 triggered + related-party map + risk grading (high risk) + disposal recommendations (suspend credit extension, report to compliance department)
Output key points:
- Core conclusion: Triggered R1 one-vote veto (clear evidence of capital circulation without real trade background), comprehensive determination of high risk
- Key risks: Capital circulation without real trade background (average 8 transfers per month, single maximum 8 million), weakened finances of the related-party group
- Handling recommendation: Immediately suspend credit, report to the compliance department, and initiate a special investigation
Out of Scope
- This skill is not responsible for credit approval decisions (it only provides related-party risk investigation results; approval decisions are handled by the credit-approval Skill)
- This skill does not perform on-site visits and on-site verification (these must be performed by the account manager)
- This skill does not handle the final write-off process for non-performing assets (this must be handled by the non-performing asset disposal system)
- This skill does not provide legal opinions (determination of the legality of related-party transactions must be performed by the legal department)
- If the user requests the above content, clearly inform them and recommend contacting the relevant department or using an appropriate tool
Output Format
Output a structured related-party graph and related-party risk report, including the following sections:
| Section | Content | Data Type |
|---|---|---|
| Basic Report Information | Report number, generation time, investigation reference time, customer name | Table |
| Related-Party List | List related parties item by item across the six dimensions (equity/management/family/transactions/guarantees/implicit), including related-party relationship type and penetration depth | Table |
| Abnormal Characteristics of Related-Party Transactions | List each identified abnormal characteristic item by item (idle fund circulation/transfer pricing/fictitious transactions/profit transfer/guarantee chain risk/fund misappropriation), including the four-flows-in-one verification results | Table |
| Related-Party Risk Assessment | Credit concentration, operational independence, guarantee chain risk, and assessment results of the financial health of the related-party group | Table |
| Risk Grading and Handling Recommendations | Risk level (high/medium/low), handling recommendations (suspend credit/increase collateral/compress limit/strengthen monitoring/normal credit) | Table |
| One-Vote Veto Trigger Status | R1-R6 trigger status (if any) | Table |
| Data Missing and Degradation Handling | Data source unavailability and degradation handling measures (if any) | Table |
Downstream Compatibility: This output can be parsed and used by the credit-approval and credit-collateral-risk-mgmt Skills.
Disclaimer: This report is for credit approval reference only and does not constitute a basis for credit decisions. Related-party transaction identification is based on available data and may be incomplete due to missing data or update delays. Reference the shared/disclaimer-template.md template.