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Screening, due diligence and case review.
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Katarina BRENVIKHigh3 source records
Matched via spelling variant “Catherine” → “Katarina”
Identity details differDOB year differs from source record · Country differs from searched country
EU Consolidated Financial Sanctions List · UK Sanctions List · UN Security Council Consolidated List
Katarina BRENVIK1 source record
Matched via spelling variant “Catherine” → “Katarina”
Country agreesCountry agreement alone does not confirm identity.
World Bank Listing of Ineligible Firms and Individuals
Kept separate from the sanctions listings because the source records assert different countries.
- Spelling
- BRENVIK on the EU and UK lists; BRENVIKA on the UN list
- Date of birth
- Full date on the EU and UK lists; year only on the UN list
- Passport
- EU list only
- Alias
- Katja BRENVIK on the UK list only
You
Propose decisions for the October onboarding batch.
AI Operator
Compared 42 listings. Proposed outcomes are ready for your review.
31proposed false positivesawaiting your approval
11need your decisionmore information needed
0approved
compared not on the listing
Your customer
Julia MarenkoPerson · United States · born 1986EU Consolidated Financial Sanctions List
Yulia MARENKOPerson · Belarus · born 1979Source record · born 1979, Minsk · Belarusian passport · listed 2022-06-03
Basis Born 1986, not 1979, and United States, not Belarus. The names link only through the spelling variant “Julia” → “Yulia”.
Proposed outcome
False positive
False positive · approved by David Miller · Undo
Subject background
Adviser to the Tollmere Senior Lending Fund, a privately offered private-credit fund available to wealth-management clients since 2022. A subsidiary of Tollmere Capital Group, Inc., which is publicly listed. [1]
Key findings
In February 2025 the adviser settled proceedings over fees an affiliate collected from fund borrowers in 2021–2023 and did not credit against the management fee, as the governing agreements required.
The order required an independent compliance consultant and a written certification of compliance within twelve months. [2]
In March 2026 the manager said the review was complete and affiliate fees are now offset in full. [3]
Counterevidence and later developments
A June 2026 report says the investor letters describe the offset only for funds launched after January 2025; the manager says each fund’s offset follows its governing agreement. [4]
Open questions
- Are borrower fees now credited against the Senior Lending Fund’s management fee, and since when?
- Has the certification of compliance been filed?
Claim being checked
Fees an affiliate collected from fund borrowers in 2021–2023 were not credited against management fees, as the governing agreements required.
Captured passage
“Contrary to the funds’ offering memoranda and governing agreements, Respondent did not offset these fees against its management fees.”
Retained source · Administrative proceeding · File No. 3-22418 · page 4 · 2025-02-11
III. Findings · ¶14 · page 4
From January 2021 through December 2023, Tollmere Loan Services LLC, an affiliate of Respondent, received $11.6 million in servicing and monitoring fees from borrowers in private credit funds Respondent advised, including the Tollmere Senior Lending Fund. Contrary to the funds’ offering memoranda and governing agreements, Respondent did not offset these fees against its management fees.
Current assessment
The manager reports its review complete [1]. Its Q3 2026 calculation for this fund credits borrower fees in full against the management fee [2]. Earlier periods are not shown.
Q3 2026 management fee calculationPDF · page 1
5Offset under section 4.3 of the governing agreement (100% of line 4)($214,300)
JWJames Walker: It covers Q3 2026 only, so it doesn’t show how earlier periods were treated.
Unresolved questions
- What do the fund’s offering memorandum and governing agreement say about the offset?
- How were borrower fees treated before Q3 2026?
- Who oversees the fee controls and the remediation today?
Colleague reviews
SCSarah CollinsReview requestedAssessment revision 3 · 2026-11-05 10:42 UTC
A colleague’s response applies to the named revision; it is not compliance clearance.
Approved-list review · Tollmere Senior Lending FundRequested by James Walker · 2026-11-05 10:42 UTC
ReviewedChanges requested
Comments
The Q3 calculation supports a credit for this fund before the reported January 2027 rollout to all funds. Confirm when it began and how earlier borrower fees were treated.
Each request applies to its named assessment revision.
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