Cross-institution trade reconciliation

The AML rail for the money laundering no single bank can see.

Mirror lets institutions jointly catch trade-based money laundering across their walls — without pooling a single customer record — and turns every decision, including the clears, into a signed record a regulator can inspect.

Not zero-knowledge. Not MPC. Blind to the operator by construction — and we say exactly where that ends.

The structural blind spot

Three legs. Three institutions. Nobody sees all three.

Trade-based money laundering is one of the largest and least-tooled laundering channels in the world, and the mechanism is simple: declare a 1,000-unit shipment at $300 a unit when it is worth $100, and $200,000 has moved out of the country under cover of a legitimate-looking trade. It stays invisible for one structural reason.

Exporter’s bank
Sees the invoice
— blind to payment & customs
Customs
Sees the declared value
— blind to invoice & payment
Importer’s bank
Sees the payment
— blind to invoice & customs
The mismatch that is the laundering belongs to no one’s alert queue. Every incumbent AML system monitors one institution in isolation — and raw data cannot be shared to fix it.
How it works

One primitive, four steps, no raw data across the wall.

01

Agree a corridor

Members agree a public reference price-band table per product. Mirror invents no prices — it only ever uses the table the parties supply.

02

Commit locally

Inside each institution a raw value becomes a band, and only a salted commitment of that band leaves the building. The raw number never crosses the wall.

03

Reconcile blind

The operator compares commitments only. It is structurally unable to read a value, because a value is never in its input.

04

Record

The verdict is signed and canonical. A flag routes to review; a clear stands as the defensible reason it was cleared.

Why this, and why now

The join across institutions is the product.

Built for the gap incumbents can’t close

Single-institution monitors cannot see across the wall by architecture. The whole value here is the join between institutions — and that is a network an incumbent’s customers cannot rebuild alone.

The rules were written for this

FinCEN 314(b), the EU’s AMLA framework and privacy-enhancing-technology sandboxes at the FCA and ICO exist precisely to enable sharing of this shape. Mirror is the tool those rules anticipated.

The clear is the product

Most AML tooling is priced on the alerts it raises. Mirror also gives you the means to defend the ones you didn’t raise — one of the hardest questions in any examination, answerable offline from the signed record.

What Mirror is — and isn’t

Stated plainly, because overclaiming is how trust dies.

A compliance team should never have to reverse-engineer what a vendor actually guarantees. These are the limits, written the same way in the product, the documentation and the pilot agreement.

Not zero-knowledge · not MPC

Blind to the operator, not to your counterparty

Salted band-commitments blind the operator, that lacks the per-shipment secret. They do not hide the band from the counterparty who shares that secret. The threat model is “don’t pool raw trade data centrally” — not “hide the two legs from each other.”

A signal, not an accusation

A divergence is a reason to look

Mirror never asserts laundering; it surfaces structure. A clear is a defensible record of why a trade was not escalated — never a guarantee of innocence.

Fail-closed toward review

Silence never buys a pass

A missing leg, an unbandable value or an unreadable commitment is undetermined — and can never clear. Ambiguity escalates, by construction.

Start with two

The network effect starts at member #2.

Land with a correspondent-banking pair — or a bank and a customs or trade-data source — who each hold one leg of the same real shipments. Run a month of historical trades through Mirror. One signed divergent verdict on a mispricing both sides individually missed is the whole proof.

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Mirror

Working name — after central-bank mirror statistics.