BLACKSWANCapital Markets OS Commercial Readiness & Client Onboarding Centre · v1.0 draft ← Return to OS Architecture
Commercial Readiness · Founder-only staging

Commercial Readiness & Client Onboarding Centre Eligibility, KYC/KYB intake, contracting, pricing, jurisdiction fit, product scope, evidence-pack coverage, and conservative go-live sequencing — all owner-named and audit-event-linked.

This Centre is internal commercial readiness workflow. Numbers below are staging / simulated commercial data. Nothing on this surface is a financial promotion, a binding commercial offer, legal advice, regulatory approval, or authorization for external launch. External institutional production remains No-Go in line with the Production Go/No-Go Board and the Launch Readiness Command Centre. Production cutover still requires Microsoft Entra OIDC with Conditional Access, RBAC/ABAC, server-side session issuance, and SIEM-forwarded audit events.

Pipeline accounts
7
Staging
Sample staging accounts across founder, board, counsel, auditor, counterparty, observer, institutional.
Commercially approved
2
Approved
Founder/Admin · Board (preview cohort).
Compliance hold / suspended
2
Hold
Counterparty Pilot suspended on MNPI binding · Institutional Client blocked.
External institutional production
No-Go
Blocked
Aligned with Production Go/No-Go Board; reissue requires every Launch Readiness gate Green.
Client launch states used on this Centre
Prospect
Identified but no qualification work yet.
Qualified
Founder-confirmed eligibility; segment assigned.
Onboarding
Owner-driven onboarding tasks in flight.
KYC / KYB Pending
Intake evidence outstanding; partner-routed where required.
Contracting
MSA / order form / DPA in review.
Commercially Approved
CCO + Risk + Founder sign-off recorded.
Technical Ready
Account provisioned; access controls primed.
Compliance Hold
Evidence drift, sanctions hit, or policy breach.
Risk-Accepted Pilot
Tightly scoped, time-boxed pilot under monitoring.
Live Internal
Internal cohort live (Founder / named internal users).
Live Controlled Pilot
Board / counsel / auditor / counterparty controlled rooms.
Live Production
Reserved state; not currently enabled for any external scope.
Suspended
Access revoked pending evidence uplift or counsel review.
Offboarded
Access archived; billing closed; post-offboarding review.
Twelve commercial readiness domains

A domain is the smallest unit that can change commercial state independently

Domains map back to Launch Readiness gates and the 21 evidence packs. Every domain has a named owner and an audit-event tag.

Domain 1
Client Eligibility Founder-confirmed target client fit; segment assignment; conflict pre-check.
Green
Domain 2
KYC / KYB Intake Identity, beneficial ownership, authorized signatory; partner-routed in ADGM/UK/EEA.
Amber
Domain 3
Sanctions / AML Screening Sanctions, PEP, adverse media checks; documented refresh cadence.
Amber
Domain 4
Contract & Terms MSA, order form, DPA, risk disclosures, MNPI terms, termination.
Amber
Domain 5
Pricing / Tiering Tier definitions, commercial approver, billing readiness, revenue recognition trigger.
Amber
Domain 6
Product Scope & Permissions Allowed evidence rooms, packs, exports; excluded internal-only annotations.
Amber
Domain 7
Jurisdiction Fit ADGM/FSRA conditional · UK FCA / MAS / MiFID/MiFID II No-Go for external.
3R · 1A
Domain 8
Counterparty / Data-Room Access MNPI policy-version binding pending; Counterparty DD room suspended.
Red
Domain 9
Operational Support On-call routes, comms tree, support SLA; founder-only today.
Amber
Domain 10
Client Success & Training Onboarding kit, training pack, MNPI obligation walkthrough, recipient acknowledgement.
Amber
Domain 11
Billing / Revenue Recognition IFRS 15 policy draft; auditor pre-clearance pending; place-of-supply for UK/EEA.
Amber
Domain 12
Post-Go-Live Review D+7 / D+30 cadence with client owner; defects, exceptions, lessons learned.
Not Started
Eight client segments / tiers

Eligibility, permitted scope, restrictions, current readiness

Segment assignment drives access to evidence rooms, distribution modes, and the pricing tier matrix below. None of these segments imply a binding commercial offer.

Founder / AdminLive Internal
Founder Admin and named internal users. Internal Preview / Internal Executive Room scope. No external surface.
Board / Regulator PrepRisk-Accepted Pilot
Named directors and FSRA pre-engagement cohort. Board Pack and Regulator Prep Bundle modes; watermarked recipient ledger required.
Professional CounterpartyCompliance Hold
Suspended on Data-Room MNPI policy-version binding. Counterparty DD Bundle non-downloadable; 30-day expiry.
Strategic PartnerOnboarding
Partner appointment evidence required (MAS); partner-route assurance attached for ADGM/UK/EEA.
Investor / ObserverLive Controlled Pilot
Named observer cohort. Investor / Observer Pack non-downloadable, per-recipient watermark, summary-only conduct MI.
Auditor / CounselOnboarding
Pre-engagement only; SOC 2 / ISAE 3402 scope letter pending. Counsel Review Bundle privileged; reviewer trail mandatory.
Institutional ClientNo-Go
External institutional production blocked. Reactivation requires every Launch Readiness gate Green and Board resolution.
Sandbox / PilotQualified
Reserved for tightly scoped sandbox cohort under supervisor pre-engagement. No live activity in scope.
Onboarding pipeline · staging accounts

Owner-named accounts with stage, blockers, and launch decision

Sample rows aligned to current Production Go/No-Go and Approval & Sign-Off posture. External institutional rows stay No-Go.

Account · owner
Jurisdiction · scope · KYC · contract · pricing · blocker · next
State
Decision
BLACKSWAN Founder Admin
Founder Admin · CISO
Jurisdiction
ADGM/FSRA (founder seat)
Scope
Internal Preview · Internal Executive Room · all packs (read-only).
KYC / KYB
Founder MFA + identity evidence on file.
Contract
n/a · internal use only.
Pricing
Tier 0 · internal.
Blocker
None.
Next
D+7 audit-chain integrity reviewer pass.
Live Internal
Conditional Go
Board Preview cohort (named)
Founder/CEO · Board Liaison
Jurisdiction
ADGM/FSRA · UK FCA · MiFID II (cadence summary)
Scope
Board Pack mode; watermarked recipient ledger.
KYC / KYB
Director identity + conflict-check on file.
Contract
NDA · board service letter.
Pricing
Tier 0 · internal.
Blocker
None.
Next
D+7 recipient ledger reconciliation.
Commercially Approved
Risk-Accepted Pilot
FSRA Regulator Prep cohort
CCO · Regulatory Affairs
Jurisdiction
ADGM/FSRA (pre-engagement)
Scope
Regulator Prep Bundle · counsel-signed limitation text.
KYC / KYB
Supervisor pre-engagement record on file.
Contract
n/a · pre-engagement only.
Pricing
Tier 0 · internal.
Blocker
UK/MAS/EEA perimeter red; FSRA-only scope.
Next
FSRA bundle scope drift monitoring.
Live Controlled Pilot
Risk-Accepted Pilot · FSRA only
External Counsel Firm
Legal / Regulatory Counsel
Jurisdiction
ADGM/FSRA · UK FCA · MAS · MiFID/MiFID II
Scope
Counsel Review Bundle · privileged work product · counsel-only.
KYC / KYB
Firm-level KYB + admitted-jurisdiction confirmation on file.
Contract
Engagement letter · NDA · privilege wording.
Pricing
Tier 0 · pass-through; no commercial revenue.
Blocker
None.
Next
UK/MAS/MiFID perimeter opinions.
Live Controlled Pilot
Risk-Accepted Pilot · counsel-only
Prospective Auditor (Big-4)
Founder Admin · CFO sponsor
Jurisdiction
ADGM/FSRA · UK FCA · MiFID/MiFID II (pre-engagement)
Scope
Auditor Evidence Pack · read-only snapshot.
KYC / KYB
Firm-level KYB pending; conflict check open.
Contract
Scope letter pending; SOC 2 / ISAE 3402 path TBD.
Pricing
Tier 0 · pre-engagement.
Blocker
Scope letter; conflict-check; engagement partner approval.
Next
Pre-engagement walk-through; reviewer signature on snapshot.
Onboarding
Defer · 2026-07-15
Counterparty DD Pilot · staging
CCO · CISO · Founder
Jurisdiction
ADGM/FSRA · UK FCA · EEA (initial cohort)
Scope
Counterparty DD Bundle · non-downloadable · 30-day expiry.
KYC / KYB
Partner-routed in ADGM/UK/EEA; MAS notice 626 alignment outstanding.
Contract
DD-room access terms in review.
Pricing
Tier 0 · pilot; no commercial revenue.
Blocker
Data-Room MNPI policy-version binding pending.
Next
Re-attest policy-version binding; reviewer pass; CCO + CISO co-sign.
Suspended
No-Go (paused)
Institutional Client cohort
Board · Founder/CEO
Jurisdiction
UK FCA · MAS · MiFID/MiFID II
Scope
Full external launch · cross-jurisdiction client onboarding.
KYC / KYB
Partner-routed pre-launch; not in scope at current Launch Readiness gates.
Contract
Not drafted; awaiting perimeter decisions.
Pricing
Tier 2/Tier 3 (not approved); commercial approver row open.
Blocker
4 of 6 Launch Readiness gates not closed; 7 P0 blockers open.
Next
Re-decision 2026-07-15; reissue requires fresh evidence and Board resolution.
No-Go
No-Go · external institutional production
KYC / KYB intake evidence checklist

Ten intake items; each owner-named and partner-routed where applicable

Sample posture aligned to the Counterparty DD Pilot. KYC/KYB itself is partner-routed today; BLACKSWAN holds the workflow, evidence, and audit trail.

✓Closed ~Partial ✗Blocking
Intake item
Owner
✓
Identity verification
Founder + named director identity evidence on file; partner-routed identity for counterparty DD.
CCO · Partner KYC vendor
~
Beneficial ownership
UBO graph drafted for counterparty cohort; partner-routed verification pending.
CCO · MLRO observer
✓
Sanctions / PEP screening
Sanctions, PEP, adverse media screening completed for active cohort; refresh cadence 90-day.
CCO · MLRO observer
~
Business activity / source of funds
Activity descriptor captured; source-of-funds detail pending for counterparty cohort.
CCO
~
Jurisdiction confirmation
ADGM/UK/EEA confirmed; MAS-cohort confirmation deferred until perimeter green.
Regulatory Affairs
✓
Authorized signatory
Authorized signer captured; board resolution where required.
Founder Admin
~
Client risk rating
Tiered risk score model defined; calibration pending against Conduct Risk MI pack.
Risk Owner
✗
Data-room entitlement
MNPI policy-version binding pending; counterparty DD room suspended.
CCO · CISO
~
Contractual authority confirmation
Counterparty officer authority confirmed; institutional cohort awaiting board resolution.
Legal Counsel
✓
Audit evidence preservation
Per-recipient ledger entry, conflict-check trail, reviewer signature captured for every grant.
CISO
Contract & commercial controls panel

Eleven contractual artefacts owner-named with current state

Production cutover for external scope requires every artefact below at Approved Internal or Live Production.

Artefact
Detail
State
MSA · Master Services Agreement
Founder-only and counsel/auditor pre-engagement templates drafted. Institutional MSA not in scope until perimeter green.
Drafting
Order form / Scope letter
Counsel engagement letter and auditor scope letter templates in flight.
Drafting
DPA · Data Processing Agreement
UK / EEA DPA templates drafted; international transfer clauses placeholder; counsel review required.
Counsel Review
Risk disclosures
Simulated/partner-routed/locked-state language; production-regulated wording reserved. Aligned with OS posture.
Approved Internal
Acceptable use policy
No reverse engineering · no external redistribution · MNPI handling; counsel-only annotations.
Counsel Review
Confidentiality · MNPI terms
Counterparty DD acknowledgement workflow; recipient ack tied to room entry; SIEM-forwarded.
Hold · MNPI binding
Liability · indemnity
Per-tier caps and carve-outs drafted; insurance evidence path documented.
Drafting
Termination · suspension
Tied to Release Control suspension triggers and Stakeholder Rooms revocation flow.
Drafting
Renewal · expiry
Default 60-day review cadence aligned with Approval & Sign-Off auto-expiry.
Drafting
Billing setup
Not enabled today. Production cutover required before any billing record. Founder/Admin pre-launch.
Pre-launch
Revenue recognition evidence
IFRS 15 policy draft; auditor pre-clearance pending; UK/EEA place-of-supply analysis open.
Auditor Review
Product scope permission matrix

Segment × surface — what each cohort can see today

Allowed cells map to a specific Stakeholder Room mode. Blocked cells reflect the current Production Go/No-Go and Stakeholder Rooms posture.

Allowed Limited Blocked Not-in-scope
Segment Board Prep Regulator Prep Evidence Rooms Data-Room Exports Counterparty DD Investor Observer Monitoring Summary Reg. Escalation Summary
Founder / Admin Allowed Allowed Allowed Limited Allowed Allowed Allowed Allowed
Board / Regulator Prep Allowed Allowed Limited Blocked Not-in-scope Limited Limited Limited
Professional Counterparty Blocked Blocked Limited Blocked Blocked Not-in-scope Not-in-scope Not-in-scope
Strategic Partner Not-in-scope Limited Limited Blocked Limited Not-in-scope Limited Not-in-scope
Investor / Observer Limited Not-in-scope Not-in-scope Blocked Not-in-scope Allowed Limited Not-in-scope
Auditor / Counsel Limited Limited Allowed Limited Not-in-scope Not-in-scope Limited Allowed
Institutional Client Blocked Blocked Blocked Blocked Blocked Blocked Blocked Blocked
Sandbox / Pilot Not-in-scope Limited Limited Blocked Limited Not-in-scope Limited Not-in-scope
Jurisdiction fit matrix · commercial availability

Where the platform is commercially available today

Commercial availability follows the Launch Readiness Jurisdiction Matrix and the Production Go/No-Go Board. None of these states imply a binding commercial offer.

Available · scope-limited Pilot only Not available Not-in-scope
Jurisdiction Internal Production Board / Regulator Prep Counsel / Auditor Counterparty DD Investor / Observer Institutional Production Notes
ADGM / FSRA Available Pilot Pilot Not available Pilot Not available FSRA pre-engagement scheduled; bundle scope agreed.
UK FCA Available Pilot Pilot Not available Pilot Not available Activity perimeter decision red; counsel opinion outstanding.
MAS Available Pilot Not-in-scope Not available Pilot Not available Partner appointment evidence + Notice 626 alignment pending.
MiFID / MiFID II Available Pilot Pilot Not available Pilot Not available EEA cross-border treatment + best-execution evidence not finalised.
Pricing / tier readiness panel

Simulated tiers, commercial approval, billing readiness, revenue trigger

Simulated tiers only. Nothing on this surface is a binding commercial offer. External-facing tiers (Tier 2/Tier 3) are not approved today.

Tier · description
Approver
Billing
Revenue trigger
External-use
Tier 0 · Internal / Pre-engagement
Founder/Admin, Board preview, FSRA pre-engagement, counsel, auditor pre-engagement.
Founder Admin
Pre-launch
n/a
Internal-only
Tier 1 · Controlled Pilot
Counterparty DD pilot · investor observer pilot. Pilot scope only; no production billing.
Founder + CCO + Risk
Held
Pilot evidence on closure
Cohort-limited
Tier 2 · Professional Counterparty
External professional counterparties post Counterparty DD close-out. Not approved today.
Board + CCO + Counsel
Blocked
IFRS 15 trigger
No external use
Tier 3 · Institutional
Cross-jurisdiction institutional production. Requires every Launch Readiness gate Green and Board resolution.
Board resolution
Blocked
IFRS 15 + place-of-supply
No external use
Go-live sequencing board

Conservative sequence aligned with Production Go/No-Go

Steps progress only when the prior step is closed on the Release Control & Rollback Centre. External institutional production remains No-Go.

Step 1
Internal / Founder Conditional Go. Founder MFA + audit chain verified.
Live Internal
Step 2
Board / Regulator Prep Risk-Accepted Pilot. Watermarked board pack; FSRA bundle scope.
Risk-Pilot
Step 3
Counsel / Auditor Counsel Review Bundle live; Auditor scope letter pending.
Live Pilot
Step 4
Counterparty DD Pilot Suspended on MNPI policy-version binding pending.
Suspended
Step 5
Institutional Production No-Go. Requires every Launch Readiness gate Green + Board resolution.
No-Go
Offboarding / suspension controls

Five triggers, each with owner, access revocation, evidence archive, billing closeout, notification path

Each row binds to the Stakeholder Rooms revocation flow and the Release Control rollback runbook.

Trigger
Action · evidence archive · billing closeout · notification owner
Owner
Audit event
MNPI / Data-Room breach
Suspend; revoke recipient tokens; recall bundle; reviewer trail captured.
Recall tokens · archive ledger · post-incident review · CCO notification path.
CCO · CISO
CR-OFF-MNPI
Sanctions / AML hit
Immediate suspension; counsel notification; MLRO observer engaged.
Revoke access · archive evidence · billing held · CCO + MLRO notification.
CCO · MLRO observer
CR-OFF-SANCTIONS
Contractual breach
Acceptable use / MNPI obligation breach; counsel review; notice issued.
Suspend access · evidence archive · billing closeout · counsel + founder notification.
Legal Counsel · Founder Admin
CR-OFF-CONTRACT
Evidence pack drift past SLA
Required evidence pack stale or red; commercial hold engaged.
Compliance hold · revoke access until reviewer pass · billing held · CCO notification.
CCO
CR-OFF-DRIFT
Jurisdiction state change
Perimeter regression on ADGM/UK/MAS/EEA invalidates commercial availability.
Suspend cohort · counsel review · billing held · Regulatory Affairs notification path.
Regulatory Affairs · Counsel
CR-OFF-JURIS
Audit trail · evidence preservation

Every commercial state change is timestamped, actor-named, and evidence-hashed

Sample audit lines consistent with current staging posture. Entries are simulated / staging evidence.

Timestamp · event
Actor
Client / segment · action · evidence · limitation · next step
Hash
2026-05-15 06:00Z
CR-QUALIFY
Founder Admin
Founder / Admin account qualified · Internal Preview scope · all packs read-only · internal-only · D+7 review.
hash:9a2c…
2026-05-15 11:48Z
CR-APPROVED
Founder/CEO · Board Liaison
Board Preview cohort commercially approved · Board Pack mode · watermarked recipient ledger · Risk-Accepted Pilot · 60-day expiry.
hash:bc40…
2026-05-15 13:22Z
CR-PILOT
CCO · Regulatory Affairs
FSRA Regulator Prep cohort live as Risk-Accepted Pilot · UK/MAS/EEA internal-only · counsel-signed limitation text.
hash:5d8f…
2026-05-15 14:25Z
CR-ONBOARD
Legal Counsel
External Counsel Firm onboarding · KYB confirmed · engagement letter signed · Counsel Review Bundle live.
hash:7e11…
2026-05-15 14:07Z
CR-SUSPEND
CCO · CISO
Counterparty DD Pilot suspended · MNPI policy-version binding pending · pack/data-room-mnpi-access · resume on CCO + CISO co-sign.
hash:e5d0…
2026-05-15 14:08Z
CR-BLOCK
Founder Admin
Institutional Client cohort blocked · external institutional production No-Go · re-decision 2026-07-15 · memo/go-no-go.
hash:3b1a…
2026-05-15 15:18Z
CR-DEFER
Founder Admin · CFO sponsor
Prospective Auditor deferred · scope letter pending · conflict-check open · 2026-07-15 re-decision.
hash:1f73…
2026-05-15 15:55Z
CR-ONBOARD
Founder Admin
Strategic Partner onboarding · partner-route assurance attached (ADGM/UK/EEA) · MAS partner appointment evidence outstanding.
hash:38ab…
2026-05-15 16:30Z
CR-GRANT
Board Liaison
Investor / Observer cohort live as Live Controlled Pilot · Investor/Observer Pack · non-downloadable · per-recipient watermark.
hash:c2e9…

Assumptions and limitations

This Commercial Readiness & Client Onboarding Centre is internal readiness workflow. All data shown is staging / simulated commercial data. It is explicitly not:

All regulated activity on the platform remains simulated, partner-routed, locked, or production-regulated as defined in the OS Architecture and Completeness Command Centre. Production cutover still requires Microsoft Entra OIDC with Conditional Access, RBAC/ABAC, server-side session issuance, and SIEM-forwarded audit events. Items shown are plausible sample states consistent with the existing Launch Readiness Command Centre, Production Go/No-Go Board, Approval & Sign-Off Workflow, Release Control & Rollback Centre, Production Monitoring & Incident Command Centre, Regulatory Notification & Board Escalation Centre, and Stakeholder Rooms & Evidence Distribution Centre; live values will be sourced from the Pack Registry once cutover is signed off.