Ironbark AML
Audit-trail surface: abstract line-work institutional reference
Methodology · v1.1

How the Ironbark Trust Score is built.

A composite 1–100 score per Australian Business Number, computed from six published sub-scores. The weights are fixed and disclosed. The data sources are named. Every field carries a last-refreshed timestamp.

Why we publish this

Compliance buyers (lawyers, accountants, real estate principals) are professionally accountable for the verification decisions they sign off on. They cannot defend a decision made against an opaque score. They can defend a decision made against a published methodology with disclosed sources and weights. Publishing the methodology is the minimum bar for a tool that any AUSTRAC reporting entity should adopt. Most of our competitors do not clear it. We do.

The six sub-scores

Sub-scoreWeight
Registration validity20
Directorship15
AUSTRAC flags20
Sanctions / PEP15
Court & insolvency15
Freshness & data integrity15
Total100

Each sub-score in detail

Registration validity

weight 20 / 100
Data source
ABR (Australian Business Register)
Refresh cadence
Daily
What it covers
ABN active status, GST registration, entity type sanity check (sole trader vs company vs trust), and incorporation date.
Edge cases
Recently-cancelled ABNs flagged for 30 days; suspended GST registration noted but not penalised if otherwise current.

Directorship

weight 15 / 100
Data source
ASIC company register, banned & disqualified persons register
Refresh cadence
Weekly
What it covers
Current directors, historical directorships, cross-director networks, intersection with the ASIC banned/disqualified register.
Edge cases
Common-name false positives are filtered using DOB + ABN context where ASIC publishes them. Where it does not, we surface the match and require user confirmation.

AUSTRAC flags

weight 20 / 100
Data source
AUSTRAC Remittance Sector Register, digital currency exchange register, published enforcement actions
Refresh cadence
Weekly
What it covers
Whether a remittance or digital currency business is registered the way the law requires, Tranche 2 applicability flag, and any published AUSTRAC enforcement action history.
Edge cases
Tranche 2 applicability is computed from ANZSIC code + entity type, not declared by the entity. Errors are corrected via per-entity feedback.

Sanctions / PEP

weight 15 / 100
Data source
DFAT consolidated list, UN Security Council list, OFAC SDN list, UK OFSI consolidated list, EU Financial Sanctions Files
Refresh cadence
Daily
What it covers
Direct and indirect intersection with five sanctions lists, plus public PEP indicators where lawful to surface.
Edge cases
Name-only matches are flagged as 'screen' not 'hit'. Confirmed matches require a second source. PEP coverage is current government office holders only; historical PEP coverage ships in Phase 2.

Court & insolvency

weight 15 / 100
Data source
ASIC insolvency register, Federal Court of Australia
Refresh cadence
Weekly
What it covers
Company external administration history and public Federal Court matters. Personal bankruptcy (AFSA) is not read: that index is a paid, name-by-name search with no bulk feed, so the input is defaulted and the API names afsa among the sources not read.
Edge cases
State court matters are out of scope for v1.0. Company insolvency events older than 7 years do not affect the score.

Freshness & data integrity

weight 15 / 100
Data source
Per-source last-refresh metadata, internal conflict detector
Refresh cadence
Continuous
What it covers
Per-field last-refreshed timestamp, count of unresolved conflicts between sources, and a stale-data penalty for any source older than its target refresh cadence.
Edge cases
If any sub-score's underlying source is more than 14 days stale, the composite score is suppressed and the report shows 'data refresh in progress'.

Score bands

The composite score maps to one of three bands. Bands are derived from the composite with one override, the band-cap rule, documented below.

GREEN80 – 100

Low risk indicators. Public-register evidence supports proceeding with ordinary customer due diligence.

AMBER60 – 79

Review recommended. Contributing risks are surfaced in the report; enhanced due diligence may be warranted.

RED0 – 59

Escalate. All contributing risks are surfaced. Enhanced due diligence or a reporting-entity obligation may apply.

Band-cap rule (v1.2)

If any non-freshness sub-score terminates at 0 (for example, a sanctions hit, an active AUSTRAC enforcement listing, a current external administration, a disqualified director, or a cancelled ABR status), the band is capped at AMBER even if the composite score otherwise lands in the GREEN range. The composite number itself is not altered; only the band classification is capped.

From v1.2 the cap depends on how the finding was joined to the business, because not all matches are equally certain. A Tier Afinding is matched on a registered identifier, an ABN or an ACN, against a regulator’s own register. One of those caps the band on its own. A Tier B finding is matched on a name, which cannot distinguish two businesses with similar trading names, so one on its own deducts and is published but does not cap the band. Two independent Tier B findings on the same business do cap it.

Every report names the tier behind each severe finding, so you can see whether we matched an identifier or matched a name.

Freshness terminal-zeros (stale data) are not caught by this rule. Stale data is a data-quality signal, not a risk-severity signal. It deducts from the composite via the freshness sub-score but does not escalate the band.

This rule was introduced at v1.1 and the evidence tiers were added at v1.2. Both apply to every Trust Score rendered from those versions forward. See the change log for the rationale and the version history.

Published beside the score, not inside it

Some checks produce a finding worth reading that we deliberately do not fold into the composite. They appear on the report as their own block, with their own source and their own as-at date, and they move no sub-score and no band.

Website to entity (.au registry)

If you give us a website alongside the ABN, we ask the .au registry who holds the licence for that domain. A com.au or net.au licence requires an Australian commercial entity, and the registry publishes the holder’s legal name and their ABN, so a website on a quote can be resolved to a legal entity. We report whether that ABN is the one you are checking.

It does not change the score, and here is why. We do not know what share of legitimate Australian businesses hold their domain under a different ABN, and it is very unlikely to be small: agencies, holding companies and directors personally all hold domains on behalf of trading entities. Scoring a signal whose normal rate we have not measured would put a number on a guess. So we publish the finding, gather the distribution, and will only revisit scoring it with data. Read a difference as a question worth asking.

The registry is read once, at the moment the check runs, for the one domain you supplied. We keep no copy of it. Every result carries the registry’s own last-modified date, because a licence can change hands the day after we read it.

What this score is not

  • Not legal advice. The score does not substitute for the judgement of an admitted legal practitioner.
  • Not a lending decision. The score is not a credit assessment, credit rating, or recommendation to extend credit.
  • Not an AUSTRAC regulatory determination. Only AUSTRAC determines reporting-entity status, enforcement outcomes, and Tranche 2 applicability in any binding sense.
  • Not a guarantee. The score is computed from publicly available registers. Errors, omissions, and stale data in those registers will flow through to the score.
Methodology v1.1 · published 2026-04-20 · IRONBARKTECH
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