Five steps. Bounded, documented, repeatable.

A priority list built from proactive targeting and a structured tip channel open to members, associations and the public. Targeting is driven by exposure rather than by notoriety: a merchant carried on a rail that also serves a hundred other shells is worth more to attribute than a single loud brand with nothing shared behind it.

Tips arrive through a structured intake so a claim can be triaged against what we can actually test. A tip that names an institution is not evidence and does not enter the collection queue as one. The list is re-ranked continuously.

Native-language entry through the affiliate funnel, correct geography and device signature, plausible deposit history. The card rail is frequently not offered at all to traffic arriving from organic search; it appears for a customer who looks like the customer the operator paid to acquire. Auditors get served the decoy.

A small real payment under a pre-set cap, set at the minimum value that reliably clears the operator's cashier. The payment exists to produce an authorisation record, not a position. No profit is taken from winnings.

Every transaction carries a full audit trail: the funnel it entered by, the timestamps, the cashier state at the moment of payment, and the authorisation and settlement records returned afterwards.

The acquiring BIN is the durable fact. A shell can change its name, its descriptor and its storefront overnight; changing the institution that acquires for it is slow, expensive and visible.

The descriptor as it lands is captured verbatim, and the orchestrator in the middle and the settlement route are reconstructed from the record. This is where a declared MCC is tested against the service actually delivered.

Chain of custody on every artefact, timestamped and reproducible, formatted for compliance-programme intake. Every named party receives a right of reply before a finding is filed, and the reply travels with the finding.