Financial Crime governed-workflow blueprints
Runtime governance blueprints for AML and financial-crime agents — transaction-monitoring alert triage and sanctions-screening hit adjudication — mapped to FATF, the EU AML package, OFAC, and the EU AI Act.
Governing a Sanctions-Screening Hit-Adjudication Agent
You govern a sanctions hit-adjudication agent by intercepting its three consequential actions — clearing a hit as a false positive (which releases a held payment or onboarding), confirming a true match (which blocks and freezes), and escalating an ambiguous fuzzy match — with a policy checkpoint that runs before the action executes, and by making the gate fail-closed on the release action rather than on the block. A clear is the irreversible, strict-liability-bearing move (an erroneous release to a blocked party is an IEEPA violation regardless of good faith), so every clear is held by default and routed to a named sanctions officer in a maker-checker gate, while the block/freeze path stays fast; binding force comes from sanctions law (OFAC's 50 Percent Rule and IEEPA strict liability, EU Reg. 269/2014 asset-freeze, the UN/FATF 'freeze without delay' standard), with the EU AI Act contributing human-oversight and logging discipline rather than an automatic Annex III high-risk classification.
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Governing an AML Transaction-Monitoring Alert-Triage Agent
You govern an AML alert-triage agent by intercepting each of its consequential actions — auto-closing an alert, escalating it, drafting a SAR/STR narrative, or writing a disposition to the case system of record — with a policy checkpoint that runs before the action executes, routing the two outcomes that change a reporting obligation (auto-close and SAR-narrative) to a named L2/L3 human in a maker-checker gate, and sealing every disposition into independently verifiable lineage. The binding obligations come from AML law (FATF R.20, EU AMLR Art. 69/73, the US BSA SAR rules) and model-risk supervision (SR 11-7); the EU AI Act contributes human-oversight and record-keeping discipline rather than an automatic high-risk classification, because AML transaction monitoring is not enumerated in Annex III.
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