Original case file
ENHANCED DUE DILIGENCE — CLOSING MEMORANDUM
Subject: Sagebrush Retail Holdings LLC
Formation: Nevada limited liability company, incorporated 11 August 2023.
Principal place of business: 6120 S Rainbow Blvd, Suite 12, Las Vegas, NV 89118.
Registered agent: Meridian Corporate Agents LLC, 2810 W Charleston Blvd, Suite 84,
Las Vegas, NV 89102.
Beneficial ownership: Dean Whitcomb (100%, contact 702-555-0231). Identity verified against
Nevada driver's licence and a utility statement dated within 90 days. No adverse media.
Business activity: Online resale of consumer electronics accessories, fulfilled through a
third-party logistics provider in Henderson, NV. The entity holds no physical retail premises.
Expected activity: 40-70 monthly card-acquirer settlements averaging $6,800, plus occasional
supplier wires to Shenzhen-based accessory manufacturers. Observed activity is within the
stated profile; supplier invoices sampled for three months and matched to outgoing wires.
Analyst note: The entity is young (under three years) and asset-light, but the business model
is coherent, the funds flow is explicable, and documentation was produced promptly on request.
Disposition: CLEARED. Annual review recommended given entity age.