Do intermediaries need to maintain the Structured Digital Database?
Every listed entity and every organization required to handle UPSI is required to maintain SDD. Fiduciaries and intermediaries like chartered accounting firms, law firms, merchant bankers and many others that are given access to or require access to UPSI to perform their role need to maintain a Structured Digital Database.
In fact, Affinisio(SDD) is, by far, the class leading Structured Digital Database for intermediaries like Merchant Bankers, Credit Rating Agencies, Private Equity or Venture Capital firms that have requirements of a higher order. These intermediaries deal with multiple restrictions, lists, deals and deal teams and Affinisio(SDD) has several additional structural features and controls designed on international best practices specifically for such organizations.
Examples:
- self-creation of multiple “Information Barriers”, permitting different deal teams within the same entity to manage projects privately, from code-names to Deal-Team level restrictions for Projects and counterparties.
- seeking and recording approvals for policy maintenance, usage of alternate KYC identifiers across jurisdictions.
- approvals for entries created by others (all senders and receivers need to approve before entries are committed to the SDD report).
- UPSI ‘super-grouping’/ ‘alternative-grouping’ to better search or respond to regulatory queries.

