Proceeds tracer
Where the money went after it landed.
We trace each disbursement from the company's account to its payees. You see how much reached the stated use and how much went to promoter-linked parties.
Private credit lenders
A term loan for stated capex (capital spending) or an acquisition. The utilisation certificate says the money went to the plant. The bank trail may say it went to a supplier registered last year.
Funds and family offices
A primary round with a stated use of funds and milestone tranches, and a founder with a broad view of what counts as working capital.
Accountants and law firms
You are preparing a use-of-funds certificate and want the bank trail behind each line before you sign.
We follow the money from the day it lands. Each payment above a threshold is traced to its payee and checked against ownership records and the stated purpose. The first trace covers 30 days and quarterly updates follow. The credit head or deal partner reads the table matching payments to purpose before releasing the next tranche.
₹1.8 cr (38% of tranche 1) paid to a supplier incorporated 7 months earlier, at a promoter entity's registered address.
Illustrative finding. Not a real company.
What lands on your desk
Fund-flow map
Each disbursement to each payee, with dates and amounts, in Excel.
Purpose match table
Payments against the stated use, variance in INR. The page the credit head reads before releasing the next tranche.
Payee profiles
Registration, filing and ownership checks for each material payee.
Related-party flags
Promoter-linked payees and money that flows back, with the evidence path.
How the work runs
Fix the purpose
From the sanction terms, term sheet or offer document, we set permitted payee categories and amounts, tranche by tranche.
Take bank consent
Bank data using the RBI Account Aggregator framework, for every account that receives or moves the money. A second account opened the week of disbursement is the first thing we look for.
Trace each payment
Each debit above threshold goes to its payee. Payees are checked for registry status, filings, signs of real operations and address, and for tax registration where the market publishes it. Transfers between the company's own accounts are followed to their end.
Overlay ownership
Payees are matched against director, shareholder and beneficial-owner data. Shared directors, shared addresses and money that returns are flagged.
Mark and report
A named analyst marks funds as applied, idle, returned or unmatched.
The stated objects
Objects of the issue from the resolution, offer letter or allotment filing, tranche by tranche.
Flows after receipt
Where the money went, by recipient, amount and date.
Recipient type
Related, newly formed, inactive, or unrelated to the company.
Two-hop trace
Onward movement from first recipients, where the bank record shows it.
Objects against actual
A side-by-side of what was promised and what happened.
Deviations
Where use differs from the stated objects, and any disclosure that follows for listed companies.
Send the offer document and pay. The company gives consent or uploads statements.
Consent link or upload.
Flows are classified and traced.
A named analyst reads each recipient and the second hop.
Baseline delivered. Each quarter after, about 24 hours.
Usually (our estimate)
Usually 2 to 3 weeks and done once, if at all, around disbursement.
Kubr
Baseline in 2 to 5 Business Days, then each update in 2 to 5.
Typical times are targets we are still testing in the pilot. The 2 to 5 day window is the commitment. Terms in Disclosures.
What the cases taught us
Misuse of raised funds appears in many of the 483 cases, and end-use tracing would have shown it in many of them.
Round-tripping appears in many cases. Money returning to a related party is visible in the flows.
The casebook includes an India case with public allegations of circular funding of a warrant issue. Those allegations are contested, and the case page links the primary documents.
Counts come from our first review of the public cases in the casebook on this site. We mapped each case, on hindsight, to the checks that could have surfaced it. It is our reading, not a finding about any company. Many cases describe allegations that are contested. See the cases
ChecksWhat we check, in plain words
| Check | What it means | An illustration (invented) | It can mislead when |
|---|---|---|---|
| Bank credits vs books | We compare the money that actually moved through the bank with the sales and costs in the books, month by month. | The books show ₹4 crore of sales in a quarter. Bank credits from customers add up to ₹2.5 crore. | AA only sees the accounts the company links, so an undisclosed account stays invisible. Cash-heavy businesses and timing differences create false flags. |
| Counterparty tax / GST | We look up the main customers and suppliers in the tax system and see whether they are active, filing, and report the same trades. | A customer the company calls its largest has not filed a return in a year. | Needs taxpayer consent or GSP access. A registered, filing shell still passes this check, which is why C3 and C4 run beside it. |
| Ownership / related-party links | We look for hidden ties between the company's counterparties and its owners, through directors, shareholders, addresses, phones and auditors. | A supplier paid ₹3 crore shares a registered address with the promoter's brother. | Nominee directors and offshore layers hide links. Name matching throws up false positives, so every flag shows its evidence path. |
| Counterparty existence | We check that each material customer, supplier or payee is a real, working business. | A vendor with ₹6 crore of invoices turns out to be a one-room office with no staff. | Real companies can be used as pass-throughs. Existence does not prove a real trade, so C6 and C7 still apply. |
| End-use tracing of funds | We follow raised money or a loan for its first 90 days and see where it went, and whether any of it reached the owners or people linked to them. | Money raised for a plant is paid out within weeks to a company the director controls. | Kubr sees only the company's own accounts. Once money reaches a third party's bank, Kubr can flag the payee but cannot see the next hop without that party's consent. |
| Operating-metric verification | We test claimed headcount, stores, vehicles, units and users against independent traces. | The company claims 800 staff. Provident fund filings show 140. | Contract staff do not appear in EPFO. Vahan access needs licensed APIs. Some businesses have no physical trace. |
What it will not tell you
- The trace needs bank consent. Without it nothing runs. If consent is withdrawn, updates cover only data already pulled, and say so.
- Once money reaches a payee's bank, we cannot follow the next hop. We flag the payee instead.
- A flag does not prove diversion. Related-party payments can be legitimate. We show the evidence path and any related-party disclosure.
- Cash withdrawals end the trail at the counter. We report their size and frequency.
Not in this service: confirm physical delivery.
What it can do
- Trace debits from every consented account to named payees, including transfers between the company's own accounts.
- Flag payees linked to promoters by directors, shareholders, addresses, emails or a shared statutory auditor.
- Flag round trips: money paid to a vendor that returns to the company or a promoter entity.
- Check each material payee's registry status, filings and signs of operations. A vendor with no operations shows.
Why it differs from the usual way
Usually
End use rests on a certificate drawn from the company's own books.Kubr
We trace end use from bank data pulled at source, payment by payment.Usually
Vendors are taken at face value from their invoices.Kubr
Each material payee is checked for existence and promoter links.Usually
Checks happen once, around disbursement.Kubr
The trace continues quarterly until the money is spent.Records we examine
| Record | What we take from it |
|---|---|
| Bank data, with consent (the RBI Account Aggregator framework) | |
| Company registry (MCA21) | |
| Tax-registration search, where the market publishes one | |
| Public employment records, where they exist | |
| Charge and security registrations (Form CHG-1 charge registrations) | |
| Company-supplied invoices (labelled as such) |
Some records need the company's consent. The report says which were pulled from source and which the company supplied.
In India
- What we pull here
- Follows drawn funds through consented bank transactions to named counterparties, checks those counterparties on GST and MCA21, and compares flows with the stated purpose.
- What is thinner here
- Only accounts the borrower consents to are visible. Other accounts are a stated gap.
What it costs
Pick the size of the deal or exposure. The fee is fixed before work starts.
₹1.25 lakh
Above the top band the fee is quoted individually. Indicative base, in local currency, before tax. All services and what moves the fee
Shape the scope
Time horizon
Entities
Speed
The fee shown for your deal size is an indicative base. A longer look-back, more entities or a faster turn moves it. The quote fixes the number before work starts.
Questions
When should the trace start?
Before the first disbursement. With consent and terms in place on day one, the trace starts at the first debit.
What counts as a related party?
Anyone linked to the promoters by directorship, shareholding, beneficial ownership, or a shared address, email or auditor in registry and tax records. Each flag shows how the link was found.
Is the report a use-of-funds certificate?
No. It is a data trace for you and your counsel or accountant. An accountant or auditor issues certificates.
What if the money sits idle?
It is marked idle, with the balance and the account. Idle funds in a promoter-linked account are reported as such. Idle funds in the company's own account are reported as unspent.
Often paired with
Start with one company.
We reply within one business day with scope, price and a date. Indicative prices in INR, before GST at 18%. Scope and price are fixed in the engagement letter.