Every sustainability claim,
governed.
The governance layer that converts fund sustainability claims into structured, evidence-linked, human-approved, supervisor-ready records. Built for FCA compliance and SFDR 2.0 preparation.
Trust & Risk Engine
Claim Governance
Governance pipeline
"The fund promotes environmental characteristics in line with Article 8 SFDR..."
25
Claim types
25
Evidence types
Deterministic
Scoring
The governance gap
The governance of sustainability claims
is fundamentally broken.
Asset managers and fund distributors publish legally consequential sustainability claims across factsheets, websites, KIDs, and SFDR disclosures. The systems governing those claims cannot withstand regulatory scrutiny.
Fragmented evidence
Methodologies, screening thresholds, and assurance statements live across disconnected systems with no structured link to the claims they support.
Invisible approvals
Sign-offs happen in email and chat threads. No structured record of who approved what, with which evidence, and which version of the claim was active.
Undetected drift
Holdings change, data vendor methodologies update, regulatory thresholds shift. Published claims can become technically unsupported without any alert.
Expensive audits
Supervisory requests require manual reconstruction of the evidence chain — slow, error-prone, and costly as FCA enforcement accelerates.
Nobody owns the fund-level claims governance workflow: taxonomy → deterministic scoring → human approval → immutable audit pack.
Dollarbaz is built for it. →
Regulatory context · 2026
Four regulatory forces.
Converging simultaneously.
This is the highest-urgency compliance environment for fund sustainability claims in history. The governance window is closing.
FCA AGR
FCA Anti-Greenwashing Rule
Live since May 2024 · First enforcement action February 2026
UK asset managers must substantiate every sustainability claim on demand. The FCA launched its first ESG-related enforcement investigation in February 2026.
SFDR 2.0
SFDR 2.0
EC Proposal November 2025 · Implementation 2027–2028
Replaces the Article 6/8/9 classification model with a stricter product categorisation regime. Only qualifying products may use sustainability-related terms. Preparation must begin now.
ESMA
ESMA Greenwashing
2026–2028 supervisory focus
January 2026 thematic notes on ESG integration and exclusion claims. Focus: fair, clear, substantiated, and up-to-date claims. Supervisory convergence tools in development.
EBA ESG
EBA ESG Risk Management
Effective January 2026
Strengthened ESG claim governance requirements for banks and asset managers. Effective January 2026.
FCA enforcement is active now. SFDR 2.0 preparation must start now.
The governance infrastructure to defend claims on demand, document approval chains, and export audit packs on request is no longer optional.
Engine 1 · Trust & Risk Engine
AI-assisted governance
for every claim.
The Trust & Risk Engine converts every sustainability claim in fund factsheets, websites, KIDs, and SFDR disclosures into structured, evidence-linked, human-approved, supervisor-ready records.
Ingest
Fund documents via paste, PDF upload, or live URL. The engine reads the full document — factsheets, KIDs, SFDR disclosures, websites.
Classify
Individual claims classified into a standardised taxonomy of 25 claim types. Evidence checklists generated per claim from pre-defined rules.
Score
Deterministic risk score 0–100 calculated from a defined flag matrix. No AI in the scoring path. Fully explainable to a regulator, line by line.
Review & Approve
Structured review workflow with full decision logging. Every approval, rejection, and version of the claim is recorded with the evidence state at time of decision.
Monitor for Drift
Alerts when evidence expires, data vendor methodologies update, or holdings changes render claims technically unsupported.
Export Audit Pack
On-demand, supervisor-ready export. Immutable, hash-chained audit trail — every state change cryptographically verifiable. Ready for FCA requests.
What the TRE is not
- ×Not a black-box greenwashing detector
- ×Not a replacement for compliance judgement
- ×Not label-dependent — works across SFDR, UK SDR, EU Taxonomy, ESRS
- ×Not AI-first — scoring is deterministic; AI assistance is optional
Architecture principle
AI assists extraction, classification, and summarisation. Rules and humans decide. Every AI action is explainable and logged.Full engine specification →
Platform
One platform.
Modular engines.
Each engine has independent scope and clear boundaries. Shared infrastructure, shared governance principles, single brand identity. Executed through narrow, high-conviction wedges.
Engine 1 · TRE
Trust & Risk Engine
Available now
Fund sustainability claims governance — extract, classify, score, approve, audit pack. FCA anti-greenwashing compliance and SFDR 2.0 preparation.
- ·Claim extraction & classification (25 types)
- ·Deterministic risk scoring 0–100
- ·Structured review & approval workflow
- ·Hash-chained immutable audit trail
- ·Supervisor-ready audit pack export
Engine 2 · FEE
Financed Emissions & Portfolio Evidence
Next engine
Governs PAI data, financed emissions disclosures, and portfolio-company ESG evidence. Same buyer, same platform — zero new sales motion.
- ·PAI data governance
- ·Financed emissions disclosures
- ·Portfolio ESG evidence profiles
- ·Two-sided network effect
Engine 3 · TRG
Treasury Router & Risk Guardian
Roadmap
Intelligent multi-rail cash routing and continuous portfolio monitoring. Different buyer profile from Engines 1 and 2.
- ·Multi-rail cash routing
- ·Continuous portfolio monitoring
- ·Risk Guardian alert framework
30-day pilot
Govern your first claims in 30 days.
We configure the taxonomy, evidence rules, and approval workflows for your fund structure. You govern the claims and hold the audit trail from day one. Measurable outcomes at day 30.
Designed for
EU/UK mid-size asset managers and fund distributors with 10–200 funds.
Pilot structure
30-day Pilot