Practice area
AML & sanctions.
Program reviews, look-backs, and tuning for transaction monitoring systems. Calibrated for the regulator who will read your next exam.
An AML program that defends itself in an examination.
The model your examiner just flagged was built in 2017.
Most AML transaction monitoring systems are calibrated once — at implementation — and then run for years on the same thresholds, the same rule sets, and the same typologies. Risk evolves; the system does not. When the examiner finally asks for a tuning study, the institution discovers it cannot produce one without an outside hand.
Our practice covers four phases of work: independent program reviews (the periodic assessment of whether the program is designed for the institution's risk profile), look-backs (transactions reanalyzed for a regulator-defined window), tuning studies (threshold and rule optimization with statistical evidence), and ongoing model validation under SR 11-7 for the institutions that have moved to ML-based detection.
We have written the report the examiner asked you to produce. The vocabulary, the structure of findings, the evidentiary standard — that is muscle memory.
The work in this practice, named.
- Independent program reviews — Risk assessment, governance, controls, training, and reporting against BSA/AML expectations.
- Look-backs — Reprocessing transactions for a defined window — typically driven by an MRA or consent order.
- TM tuning & threshold studies — Below-the-line testing, above-the-line testing, alert-to-SAR conversion analysis.
- Sanctions screening — List management, name/transaction screening calibration, false-positive analysis.
- Rule set & typology refresh — New typologies (crypto on-ramps, layering through fintech rails), retired typologies, calibration.
- CDD / EDD program design — Risk rating models, periodic refresh cadences, high-risk customer governance.
A typical tuning engagement.
| Phase | Timing | Deliverable |
|---|---|---|
| Data & scope | Weeks 1–2 | Transaction data pulled, alert history reviewed, scope of tuning agreed. |
| Statistical study | Weeks 3–6 | Below-the-line and above-the-line testing; threshold sensitivity analysis. |
| Recommendations | Weeks 7–8 | New thresholds, retired rules, new typologies, governance changes. |
| Documentation | Weeks 9–10 | Tuning report, methodology memo, executive briefing for the BSA officer and the committee. |