Counterparty screening as a written rule.

The rule, stated.

The rule is published, not internal. It is the standing rule governing every counterparty MSIFS engages with — every shareholder above 5%, every board member, and every UBO traced to the second tier.

Why a published rule, not an internal one.

Three reasons.

1. LP DDQ defensibility. When an institutional LP asks how MSIFS would have screened a specific named counterparty, the answer is in writing, dated, and identical to the answer they would have received six months earlier. There is no ambiguity about whether the rule was applied.
2. Single-person risk reduction. The rule does not depend on any one partner being in the room. Any GP or staff member can run the screen. The institutional knowledge about who is on the Ukraine NSDC list, why, and when, lives in the firm-level decision log — not in someone's head.
3. Compounding learning. Each time a counterparty is screened, the rule's reference dataset grows. The next deal benefits from the last one's diligence.

What the screen actually checks.

The screen runs against five canonical sanctions lists:

• OFAC SDN — US Treasury Office of Foreign Assets Control Specially Designated Nationals list
• UN Security Council Consolidated List
• EU Consolidated List of Persons, Groups and Entities Subject to EU Financial Sanctions
• UK HMT (HM Treasury) Consolidated List
• Ukraine NSDC sanctions list — added explicitly because the war made Ukraine NSDC a meaningful jurisdiction for Western LP capital

The reputational layer adds: short-seller research (Hindenburg, Muddy Waters, Citron, etc.), regulatory enforcement actions (SEC, FCA, FINRA, MAS), and corporate-governance-incident databases. A positive hit on any of these triggers GP committee escalation.

How bRRAIn runs it.

The screen is a bRRAIn operating routine. It runs automatically before any deal is staffed beyond initial screening. It traces UBO chains to the second tier. It cross-references against MSIFS's own prior decision log to surface relevant precedent (prior precedent: the Ai Karaaul opportunity assessment established our canonical reference case for Turlov-related counterparty risk).

A typical screen output looks like this:

What it does not do.

does not replace partner judgment. A clean screen is not a green light — it is the absence of a red light. The deal still has to clear the published deal screen, the country thesis, the Pillar I/II/III pairing rule, and the GP committee. is necessary, not sufficient.

also does not prevent a counterparty from improving over time. Sanctions designations get lifted. Short-seller allegations get rebutted. The rule includes a quarterly refresh cadence so a counterparty that was blocked in 2026 can be re-screened in 2027 if the sanctions or reputational status materially changes.

Why this matters to LPs.

Every LP DDQ in 2026 contains some version of the question: "How do you screen counterparties for sanctions, reputational, and ESG risk?" Most fund managers answer with a process description. MSIFS answers with a published rule, a dated decision, a named precedent, and a bRRAIn-generated audit trail of every counterparty ever screened.

That is the wedge. The institutional LP is not buying our intent to screen. They are buying our structural inability to forget.