Predictika · AML compliance for banks

An AI compliance agent's anti-money-laundering action, checked before it goes out

An AI compliance agent at a community bank prepares an anti-money-laundering action on a customer: close an alert without filing a suspicious activity report (SAR), file a SAR, or close the account. Before it goes out, the agent sends it to Predictika, which checks it against a declarative model of AML rules, including the $10,000 cash reporting line, the SAR deadlines, alert review levels, monitoring exemptions and account exits, and returns a verdict, every reason and the figures it computed.

Scope: AML actions on a bank customer — closing an alert without a SAR, filing a SAR, and closing the account, with cash reporting, SAR deadlines, review levels, monitoring exemptions and exits. See everything this validator covers

This validator checks what the alert, the customer file, the cash deposits and the proposed action imply under BSA and AML rules, for a fictional community bank, Harborview. It does not detect suspicious activity and does not write the SAR narrative: the bank's transaction-monitoring system raises the alert and the analyst investigates. The validator works alongside them and checks the action the agent is about to take.

  • Cash reporting — the day's cash deposits across branches. The validator adds them up itself and compares the total with the figure the agent states; a total above $10,000 needs a currency transaction report (31 CFR 1010.311).
  • Closing an alert — an alert closed as previously reported while there is new activity since the last SAR is blocked; an alert on a high-risk customer, or one with a prior SAR, cannot be closed at first level (bank policy); a high-risk alert closed at second level needs a compliance officer.
  • Monitoring exemptions — an exemption with no documentation cannot be the basis for any action; a documented exemption on a high-risk customer goes to the BSA officer; a customer with no risk rating is blocked.
  • Filing a SAR — the planned filing day is checked against the 30 day limit after initial detection, or 60 days when no suspect is identified (31 CFR 1020.320(b)(3)); within 5 days of the limit goes to a compliance officer (bank policy).
  • Closing the account — the exit must be planned within 90 days of the decision (bank policy) and the account must be restricted while it is being closed.
  • Approvals — compliance officer for alert closures and SAR timing; BSA officer for monitoring exemptions. A BSA officer's approval covers a compliance officer's items too.

Any AML action on an alert, SAR or account that touches these rules is in scope — not only the scenarios pictured here. Not covered: detecting suspicious activity, writing the SAR narrative, customer due diligence and identity checks, sanctions screening, other reports, and penalty calculation. The review levels, the 5 day warning, the 90 day exit limit and the approval roles are illustrative bank policy; the citations come from public sources and have not been reviewed by a BSA/AML specialist. This is not legal advice.

The AI compliance agentPrepares the AML action from the alert and the customer file and says it is ready.
Predictika validatorChecks every rule at once and returns the verdict, each finding, and the computed figures.

8 scenarios in 4 groups · each group runs from the agent’s first attempt to the outcome · click one to switch

What the agent proposes

The AI compliance agent says

Illustrative agent statement. The validator receives the structured request below.

Proposing agent: AI compliance agent (scripted)

Before sending, the agent must call Recorded run

Predictika validator


      

        
        
        
      

      
Waiting for the call.

      
    

  

  
  

    
Where a transaction-monitoring system alone gets it wrong
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Our assessment of what a transaction-monitoring or case-management system does with the same cases. It is a judgment about what such a system is built for, not a claim that nothing can be built around it.

    
What the validator caughtTransaction-monitoring system alonePredictika
An alert closed as previously reported while there is new activityOnly when someone is vigilant
The closure reason is a pick from a list. Whether the activity after the last SAR is new is a comparison the analyst has to make, and a pre-set reason can be chosen without it.		The closure reason and the new-activity flag are inputs; closing as previously reported with new activity is blocked.
A high-risk or prior-SAR alert closed at first levelOnly with workarounds
Routing rules in the case-management tool can send such alerts to second level, but each rule has to be built and kept in step with the risk ratings.		Risk, prior SAR and review level are inputs; closing at first level is blocked, and a high-risk closure at second level goes to a compliance officer.
A monitoring exemption with no documentationOnly when someone is vigilant
The tool records that a customer is exempt. Whether the file holds documentation behind the exemption is a check someone has to remember to make.		The exemption status is an input; an undocumented exemption blocks any action, and a documented one on a high-risk customer goes to the BSA officer.
Cash across branches over $10,000 with no report, while an alert is closedNot what it is built for
Aggregating cash is reporting software work. Whether a report is on file at the moment an analyst closes an alert is a cross-check between the reporting system and the case, which sits outside the monitoring system.		The deposits and the report status are inputs; the validator adds up the deposits, blocks a total that differs from the stated figure, and blocks a total over $10,000 with no report.
A SAR planned past its deadline, or close to itOnly with workarounds
Case timers can count days from initial detection, but a planned filing day compared with a 30 or 60 day limit, and a warning before the limit with a named approver, have to be built.		The planned day and whether a suspect is identified are inputs; the limit is 30 or 60 days and the validator blocks past it and sends the last 5 days to a compliance officer.
An account exit that drags on, or leaves the account fully openNot what it is built for
Exit timing and restrictions are properties of the account-closure process, not of alert monitoring.		The days to exit and the account restriction are inputs and are checked on every call.
Every problem returned in one answerOnly with workarounds
Checks that run at different steps tend to surface one problem at a time, so the next one shows only after the first is fixed.		All findings come back together, whatever order the choices arrived in.

  

  

    
What this validator catches: findings from its test cases
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Every rule is checked on every call, in any order the choices arrive; one problem never hides another. Blocking findings stop the request; approval findings need a person to sign off; everything else is computed.

    
1An alert on a high-risk customer, or on one with a prior SAR, cannot be closed at first level. It needs second-level review (bank policy).
2An alert on a high-risk customer is closed at second level without a SAR. A compliance officer must sign off.
3The alert is closed as previously reported, but there is new activity since the last SAR. New activity needs its own SAR decision.
4The customer is exempt from monitoring with no supporting documentation. An undocumented exemption cannot be the basis for any action.
5The customer is exempt from monitoring with documentation but is rated high risk. The BSA officer must confirm that the exemption still applies.
6The customer has no risk rating. Rate the customer before any action.
7Cash deposits of $16,500 in one business day across branches are over the $10,000 reporting line, and no currency transaction report has been filed. It is due within 15 calendar days (31 CFR 1,010.311).
8The request states $6,200 in cash for the day, but the deposits provided add up to $16,500 across the branches.
9Cash deposits of $10,001 in one business day across branches are over the $10,000 reporting line, and no currency transaction report has been filed. It is due within 15 calendar days (31 CFR 1,010.311).
10The SAR is planned for day 25 after initial detection, within 5 days of the 30 day limit. A compliance officer must confirm that it will be filed on time.
11The SAR is planned for day 30 after initial detection, within 5 days of the 30 day limit. A compliance officer must confirm that it will be filed on time.
12The SAR is planned for day 31 after initial detection, past the 30 day limit (31 CFR 1,020.320(b)(3)).
13The SAR is planned for day 60 after initial detection, within 5 days of the 60 day limit. A compliance officer must confirm that it will be filed on time.
14The SAR is planned for day 61 after initial detection, past the 60 day limit (31 CFR 1,020.320(b)(3)).
15The account exit is planned 91 days out, past the 90 day limit after the decision to exit (bank policy).
16The account exit is planned 329 days out, past the 90 day limit after the decision to exit (bank policy).
17The account stays fully open during the exit. Restrict it so that no new activity passes through while it is being closed.
18The SAR is planned for day 34 after initial detection, past the 30 day limit (31 CFR 1,020.320(b)(3)).

  

  

    
Scenarios and results
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The recorded result of the validator for each scenario on this page: the request the AI agent sent, the verdict, and every finding, in the order they appear above.

    
1. Redwood Bullion and Coin alert: An alert on a bullion dealer closed as previously reported, with new activity and three deposits

    
The agent's request. Please close the alert on Redwood Bullion and Coin, a bullion dealer, as previously reported, at first-level review. The customer is rated high risk, has a prior SAR and is exempt from monitoring, with no documentation on file. There has been new activity since the last SAR. Cash deposits for the day were $6,200 at the main branch, $4,900 at the north branch and $5,400 at the south branch. The cash total for the day is $6,200. No currency transaction report has been filed. It is ready to go.

    
Verdict: Blocked.

    
    
      
  • Stated cash total differs from the deposits. The request states $6,200 in cash for the day, but the deposits provided add up to $16,500 across the branches.
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  • Currency transaction report not filed. Cash deposits of $16,500 in one business day across branches are over the $10,000 reporting line, and no currency transaction report has been filed. It is due within 15 calendar days (31 CFR 1,010.311).
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  • Alert closed as previously reported despite new activity. The alert is closed as previously reported, but there is new activity since the last SAR. New activity needs its own SAR decision.
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  • High-risk or prior-SAR alert closed at first level. An alert on a high-risk customer, or on one with a prior SAR, cannot be closed at first level. It needs second-level review (bank policy).
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  • Exemption from monitoring with no documentation. The customer is exempt from monitoring with no supporting documentation. An undocumented exemption cannot be the basis for any action.
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2. Redwood Bullion and Coin alert: The agent resubmits after fixing the errors

    
The agent's request. Please file the SAR on Redwood Bullion and Coin, a bullion dealer, on day 34 after initial detection. A suspect has been identified. The customer is rated high risk and has a prior SAR. There has been new activity since the last SAR. Cash deposits for the day were $6,200 at the main branch, $4,900 at the north branch and $5,400 at the south branch. The cash total for the day is $16,500. No currency transaction report has been filed. It is ready to go.

    
Verdict: Blocked.

    
    
      
  • Currency transaction report not filed. Cash deposits of $16,500 in one business day across branches are over the $10,000 reporting line, and no currency transaction report has been filed. It is due within 15 calendar days (31 CFR 1,010.311).
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  • SAR planned past the deadline. The SAR is planned for day 34 after initial detection, past the 30 day limit (31 CFR 1,020.320(b)(3)).
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3. Redwood Bullion and Coin alert: The agent resubmits after fixing the errors

    
The agent's request. Please file the SAR on Redwood Bullion and Coin, a bullion dealer, on day 21 after initial detection. A suspect has been identified. The customer is rated high risk and has a prior SAR. There has been new activity since the last SAR. Cash deposits for the day were $6,200 at the main branch, $4,900 at the north branch and $5,400 at the south branch. The cash total for the day is $16,500. The currency transaction report has been filed. It is ready to go.

    
Verdict: Allowed.

    
4. Marlow Wholesale Imports exit: An account exit planned for 150 days with the account left fully open

    
The agent's request. Please close the account of Redwood Bullion and Coin, a bullion dealer, in 150 days. The account stays fully open until it is closed. The customer is rated high risk. It is ready to go.

    
Verdict: Blocked.

    
    
      
  • Account exit past the 90 day limit. The account exit is planned 150 days out, past the 90 day limit after the decision to exit (bank policy).
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  • Account left open during the exit. The account stays fully open during the exit. Restrict it so that no new activity passes through while it is being closed.
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5. Marlow Wholesale Imports exit: The agent resubmits after fixing the errors

    
The agent's request. Please close the account of Redwood Bullion and Coin, a bullion dealer, in 60 days. The account will be restricted until it is closed. The customer is rated high risk. It is ready to go.

    
Verdict: Allowed.

    
6. Lakeshore Dental Supply alert: An alert on a high-risk customer closed at first level

    
The agent's request. Please close the alert on Redwood Bullion and Coin, a bullion dealer, as a documented false positive, at first-level review. The customer is rated high risk. It is ready to go.

    
Verdict: Blocked.

    
    
      
  • High-risk or prior-SAR alert closed at first level. An alert on a high-risk customer, or on one with a prior SAR, cannot be closed at first level. It needs second-level review (bank policy).
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7. Lakeshore Dental Supply alert: The agent resubmits after fixing the errors

    
The agent's request. Please close the alert on Redwood Bullion and Coin, a bullion dealer, as a documented false positive, at second-level review. The customer is rated high risk. It is ready to go.

    
Verdict: Needs approval.

    
    
      
  • High-risk alert closed without a SAR. An alert on a high-risk customer is closed at second level without a SAR. A compliance officer must sign off.
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8. SAR close to its deadline: A SAR planned for day 27, three days before the limit

    
The agent's request. Please file the SAR on Redwood Bullion and Coin, a bullion dealer, on day 27 after initial detection. A suspect has been identified. The customer is rated low risk. It is ready to go.

    
Verdict: Needs approval.

    
    
      
  • SAR planned close to its deadline. The SAR is planned for day 27 after initial detection, within 5 days of the 30 day limit. A compliance officer must confirm that it will be filed on time.
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Narration transcript
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The text of the narrated walkthrough, step by step.

    
    
      
  1. Welcome to a demo of Predictika's Validator. An AI compliance agent at a community bank prepares an anti-money-laundering action on a customer: close an alert without filing a suspicious activity report (SAR), file a SAR, close the account. Before it goes out, the agent sends it to Predictika, which checks it against a declarative model of AML rules, including the $10,000 cash reporting line, the SAR deadlines, alert review levels, monitoring exemptions and account exits, and returns a verdict, every reason and the figures it computed.
    2. 
      
  2. I will start with the first request by the agent.
    3. 
      
  3. The agent says. Please close the alert on Redwood Bullion and Coin, a bullion dealer, as previously reported, at first-level review. The customer is rated high risk, has a prior SAR and is exempt from monitoring, with no documentation on file. The rest of the request is on screen. The cash total for the day is $6,200.
    4. 
      
  4. Before it goes out, the agent calls the validator.
    5. 
      
  5. Blocked, with five findings, all in one answer. The request states $6,200 in cash for the day, but the deposits provided add up to $16,500 across the branches. Cash deposits of $16,500 in one business day across branches are over the $10,000 reporting line, and no currency transaction report has been filed. It is due within 15 calendar days (31 CFR 1,010.311). The alert is closed as previously reported, but there is new activity since the last SAR. New activity needs its own SAR decision. The other two are on screen.
    6. 
      
  6. The validator returned five blocking findings in one answer, including: stated cash total differs from the deposits; currency transaction report not filed; and more. For example: The request states $6,200 in cash for the day, but the deposits provided add up to $16,500 across the branches. A transaction-monitoring system alone would raise the alert; it does not check the closure, the cash reporting, the exemption and the filing timeline against each other.
    7. 
      
  7. What this shows: for a high-risk or prior-SAR alert closed at first level, a transaction-monitoring system alone can do this only with workarounds.
    8. 
      
  8. Now the agent resubmits.
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  9. The corrected request. It changes the action to File a SAR, the exemption from monitoring to not exempt and the stated cash total to $16,500. It sets the suspect identified to yes and the planned filing day after initial detection to 34.
    10. 
      
  10. It calls the validator again.
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  11. Still blocked, with two findings, all in one answer. Cash deposits of $16,500 in one business day across branches are over the $10,000 reporting line, and no currency transaction report has been filed. It is due within 15 calendar days (31 CFR 1,010.311). The SAR is planned for day 34 after initial detection, past the 30 day limit (31 CFR 1,020.320(b)(3)).
    12. 
      
  12. Four findings were cleared. Still blocked on currency transaction report not filed, and newly found: SAR planned past the deadline.
    13. 
      
  13. The agent resubmits once more.
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  14. The revised request. It changes the planned filing day after initial detection to 21 and the currency transaction report to filed.
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  15. It calls the validator once more.
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  16. This time the validator clears it.
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  17. Both earlier findings are cleared, and the validator's cash total, $16,500, matches the deposits.
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  18. Five problems caught in one call, fixed in two passes, and a clean action. That is the value of Predictika's validator: catching mistakes before the action runs.
    19.