identity-canon/research/commercial-identity/commercial-identity-nuance-settlement.md

Commercial Identity Nuance Settlement (2026)

Source Type

identity-canon adjudication note — resolves remaining open questions and "remaining nuance" items across the commercial-identity research stack.

Domain

Standard enums, cross-registry linking rules, regulatory layering, and adapter guidance for commercial identity edge cases.

Beneficial Ownership Nuances

control_basis enum (settled)

Use a jurisdiction-neutral role code on Beneficial Ownership Relationship, plus regulatory_basis for program-specific rules.

control_basis	Typical sources
senior_managing_official	FATF generic; US CDD control prong when no other role fits
chief_executive	CEO, managing director, president, executive director
chief_financial	CFO, treasurer with control
managing_member	LLC managing member
general_partner	Partnership general partner
board_chair	Chair with operational control
trustee	Trust with management control
settlor_with_control	Settlor retaining control over trust
other_control	Catch-all — require control_basis_detail free text

regulatory_basis values: us_cdd, us_boi_cta, eu_amld, fatf_r24, national_statute.

US CDD "significant responsibility to control, manage, or direct" maps to the most specific code available, else senior_managing_official. EU AMLD "senior managing official" maps directly. Store one control-prong person per US CDD rule; multiple ownership-prong persons allowed.

FinCEN ID (settled)

FinCEN ID for BOI filers maps to Registry Identifier:

• authority_class: government_registry
• scheme: fincen_individual_id (or jurisdiction-specific extension)
• jurisdiction: US
• Attached to Natural Person, not Organization.

Exempt legal entity customers (settled)

Do not rely on absence of Beneficial Ownership Relationships. Record explicit Beneficial Ownership Exemption as Evidence Source on the Legal Entity / Organization with:

• exemption_type: publicly_traded, government_entity, regulated_financial_institution, subsidiary_of_exempt_parent, other
• regulatory_basis, evidence_reference, lifecycle_state

Absence alone is ambiguous (not collected vs. exempt vs. not applicable).

BOI filing volatility vs. CDD (settled)

Separate regulatory layers in canon — do not merge:

Layer	Canon artifact	Volatility
CDD beneficial ownership	Beneficial Ownership Relationship	Stable for covered FIs; collection obligation endures
BOI registry filing	Evidence Source (evidence_type: boi_filing)	Jurisdiction-dependent; track lifecycle downstream
Transparency registry	Evidence Source (evidence_type: bo_registry_extract)	Per national register

Canon does not prescribe legal outcomes; downstream adapters apply current statute. CDD relationships remain even when BOI filing requirements change.

Registry Identifier Nuances

authority_class extension (settled)

Add industry_association for identifiers issued by trade, standards, or procurement bodies without government incorporation authority:

• NCAGE / CAGE (defense supplier ID)
• GS1 GLN when used as organization/location key in supply chain

Retain government_registry, regulatory_global, commercial_proxy, tax.

Cross-registry Synonymity strength (settled)

Link	Default strength	Notes
LEI ↔ national company reg / ALEI	strong	Same legal entity when LOU or government register confirms
LEI ↔ UEI	strong	When SAM.gov or authoritative crosswalk confirms
LEI ↔ DUNS	medium	D&B may assign per location; proxy authority
DUNS ↔ UEI	medium	Historical procurement migration
DUNS ↔ company reg	medium	Branch/location mismatch common
company reg ↔ ALEI	authoritative	Same register encoding

Use relation_type: same_as when strength is strong or authoritative; linked_to for medium. Require evidence_reference (crosswalk, operator verify).

ISO 6523 OPI / branch modeling (settled)

ISO 6523 organization part identifier (OPI) models a branch or org unit, not a separate legal entity by default:

• Store OPI on Registry Identifier as optional organization_part_id.
• Map branch to Organization Unit (Group specialization) or child Organization when operationally distinct.
• Branch DUNS + parent LEI: link branch Proxy Commercial Identifier to parent Organization via structural relationship; Synonymity Assertion (medium) between branch DUNS and parent LEI when same legal entity confirmed.

Reputation and Assurance Nuances

assurance_tier vs. numeric score (settled)

Primary: assurance_tier enum (opinion | observed | committed | adjudicated).

Optional: numeric_score + score_scale on Evidence Source for downstream (e.g., PAYDEX 0–100, star rating 1–5). Downstream maps score ranges to tiers; canon does not merge tiers from scores alone.

Platform escrow without separate contract (settled)

Segregated escrow with defined release conditions is committed tier:

• Model Commercial Commitment commitment_type: escrow
• Evidence Source: platform escrow terms, payment-provider escrow object, or marketplace buyer-protection policy accepted at transaction time
• Funds segregation + conditional release = commitment, not merely observed metric

Cross-platform reputation portability (settled)

Portable reputation uses Synonymity Assertion between Reputation Signal Evidence Sources:

• Default relation_type: linked_to (not same_as)
• Default strength: weak
• Upgrade to medium only with verified identity bridge (same Natural Person proof, verified purchase on both platforms, operator confirmation)
• Require portability_evidence reference; scope must list both platforms

Smart-contract / oracle outcomes (settled)

Outcome type	Tier	Canon
On-chain condition check (oracle, escrow release)	observed	Performance Evidence
Binding ADR with identified parties (incl. on-chain tribunal with published rules)	adjudicated	Adjudication Outcome
Court judgment enforced on-chain	adjudicated	Adjudication Outcome

Automation alone does not elevate to adjudicated without identifiable dispute authority and parties.

Payment Nuances

Network tokens e.g. Visa VTS (settled)

Network tokens map to Payment Instrument Reference:

• instrument_type: network_token
• network_token_service (e.g., visa_vts, mastercard_mdes)
• Same lifecycle and PCI boundary as pm_xxx references

Shared payment methods across org customers (settled)

One Payment Instrument Reference may attach to multiple Commercial Records within the same payment-provider org Scope:

• sharing_scope: payment_provider_org
• shared_across_records: [commercial_record_ids]
• Do not Synonymity-merge Commercial Records — only share the instrument reference

Customer wallet balance (settled)

Provider ledger balance (Stripe Customer balance) is a Commercial Record attribute provider_ledger_balance — not a Credential, not a Commercial Commitment. Currency and provider scope required.

CRM and Pipeline Nuances

binding_trigger enum (settled)

Value	Commitment state	Typical evidence
quote_accepted	proposed	CPQ acceptance, e-sign
loi_signed	proposed	Signed LOI
purchase_order_executed	active	PO record
contract_executed	active	Signed agreement
subscription_activated	active	Billing webhook
regulatory_onboarding_complete	active	KYC/KYB completion
org_policy_closed_won	active only if org maps Closed Won → executed contract and policy documented as Evidence

org_policy_closed_won is downstream-configured; canon requires explicit Evidence.

Renewal Opportunity (settled)

Situation	Canon treatment
Renewal on existing contract (same agreement extended)	Commitment amendment Evidence on existing Commercial Commitment; optional Pipeline Pursuit for forecast tracking
Competitive rebid / new agreement cycle	New Pipeline Pursuit
Material term change	Commitment amendment + may create Pipeline Pursuit

Rule: if amends_commitment_id is set and change type is renewal or amendment, do not create a new root Commercial Commitment unless terms are net-new contract.

Partner vs. customer Opportunity (settled)

Same Pipeline Pursuit type with pursuit_role:

• customer (default)
• partner (channel, alliance)
• vendor (reverse sourcing)

Role affects Commercial Relationship typing, not Pipeline Pursuit structure.

Person Account adapter guidance (settled)

Salesforce Person Account and similar B2C shortcuts:

• Canon storage: Natural Person + Commercial Record (split layers)
• Adapter projection: projection_mode: person_account_combined on export only
• Do not introduce Person Account as canonical root; discourage unified tables in downstream schema without layer tags

eIDAS / EUDI Nuances (commercial stack)

Qualified electronic seal (settled)

Maps to Credential with credential_type: qualified_seal, bound to Organization / Legal Entity through Representation Relationship (signing officer or mandated agent). Distinct from login Credential.

EUDI organizational wallet Scope (settled)

Organizational wallet is a Scope specialization (wallet_scope) holding wallet-hosted Credentials and Claims — not a Tenant (no admin isolation semantics). Link wallet Scope to Commercial Record and Organization actor via Commercial Relationship.

References

All prior commercial-identity source notes. This note supersedes their Open Questions sections where marked settled below.