Evidence first
Every conclusion should point to a primary document, official record, executed agreement or documented factual analysis.
Controlled Record · CMP-REG
Compliance Review Register
A fact-specific control register for tax, nonprofit, regulatory, licensing, related-party, funding and jurisdictional review before material activities or transactions are approved.
Control boundary: This register does not itself establish tax status, exemption, licensing, legal authority or compliance. Each conclusion must be supported by the actual facts, governing documents and applicable professional or regulatory review.
Review Matrix
Compliance gates
Use the register to identify the question, evidence required, reviewer and disposition. Do not convert a proposed structure into a compliance conclusion merely because it appears in the architecture.
| ID | Review Area | Applies To | Question | Evidence Required | Reviewer | Disposition | Approval / Exception | Next Action | Status |
|---|---|---|---|---|---|---|---|---|---|
| CMP-001 | Entity formation | All entities | Does each entity legally exist in the stated form and jurisdiction? | Formation/registration record + governing document | Records / counsel | TBD | TBD | Verify primary records | PENDING |
| CMP-002 | Authority | Material agreements and transactions | Are the parties and signatories authorized? | Bylaws/operating agreement, resolution, delegation | Governance | TBD | TBD | Confirm authority before execution | PENDING |
| CMP-003 | Nonprofit purpose | Foundation activities | Is the activity consistent with the organization's actual governing purpose? | Governing instrument + programme record | Governance / tax adviser | TBD | TBD | Document purpose analysis | PENDING |
| CMP-004 | Private benefit / inurement | Foundation-related arrangements | Could the arrangement confer impermissible private benefit or inurement? | Terms, pricing, conflict disclosures, approvals | Governance / tax adviser | TBD | TBD | Independent review where material | PENDING |
| CMP-005 | Related organizations | Inter-entity relationships | Does the actual relationship trigger related-organization analysis? | Ownership/control/governance facts + agreements | Tax / accounting | TBD | TBD | Assess applicable Form 990/Schedule R treatment | PENDING |
| CMP-006 | Unrelated business activity | Commercial operations | Does an activity require unrelated business income analysis? | Activity facts, frequency, revenue/expense records | Tax / accounting | TBD | TBD | Document tax treatment | PENDING |
| CMP-007 | Grant restrictions | Donations / grants / research | Are funds used consistently with donor or grant restrictions? | Award/gift terms + restricted-fund ledger | Finance / programme lead | TBD | TBD | Map restrictions to expenditures | PENDING |
| CMP-008 | Sector licensing | Aquaculture, food, water, energy and other regulated activity | Are required permits, registrations and inspections identified? | Applicable licenses, permits and inspections | Compliance / operations | TBD | TBD | Confirm jurisdiction-specific requirements | PENDING |
| CMP-009 | Finance / AML-KYC | Loans, capital, payment and finance interfaces | Are applicable financial, AML/KYC and counterparty requirements satisfied? | Instrument, counterparty and source-of-funds records | Finance / compliance | TBD | TBD | Complete applicable diligence | PENDING |
| CMP-010 | Data / IP | Research and technology | Are data, privacy, publication and IP rights properly documented? | R&D agreement, IP/data policy, consent or license records | Research / legal | TBD | TBD | Resolve rights before release | PENDING |
| CMP-011 | Insurance / risk | Assets and operations | Are ownership, custody, liability and insurance responsibilities allocated? | Policies, certificates, agreements and risk assessment | Operations / risk | TBD | TBD | Close identified gaps | PENDING |
| CMP-012 | Jurisdiction | Cross-border operations | Are applicable local and cross-border requirements identified? | Entity locations, activities and professional analysis | Compliance / counsel | TBD | TBD | Complete jurisdiction matrix | PENDING |
Escalate uncertainty
Material ambiguity is an OPEN item, not an implied approval. Escalate to qualified counsel, tax or regulatory professionals where appropriate.
Separate facts from assumptions
Keep proposed structures, anticipated activities and actual completed transactions separately identified.
Record exceptions
Any exception should identify its approving authority, scope, duration, conditions and remediation path.
Reporting note: Where a U.S. Form 990 filer is involved, related-organization and transaction reporting should be evaluated from the actual control and transaction facts. This page is an internal control framework, not a tax determination.
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