Transaction Monitoring
TM-09

Report rule performance monthly and calibrate at 90 days, then yearly

Policy reference

Transaction Monitoring policy, §8.1, §10

FFIEC BSA/AML Examination Manual, Suspicious Activity Reporting
Requirement

Each month the Company delivers an operating report to the sponsor bank with rule-level alert counts, the false positive rate, the disposition mix, open case and referral aging, and any threshold breaches. The AML Compliance Officer conducts a formal calibration review of every threshold 90 days after launch and annually thereafter, evaluating alert volume and false positives by rule, referral rate by rule, typologies no rule covers, the bank’s feedback on package quality, and current regulatory guidance, and records the findings and any changes in a calibration memo.

Trigger

Monthly

Monthly operating report; calibration review at 90 days after launch and annually

Action

Compile the rule-level figures each month and send the report to the bank; at each calibration review, test every threshold against live data, note uncovered typologies, and write the memo.

Evidence
  • Monthly operating report

    Rule-level counts, false positive rate, dispositions, aging, breaches, as sent to the bank

  • Calibration memo

    Findings per rule, threshold changes, bank feedback, Officer’s approval

Owner

AML Compliance Officer

Work and review
Prepare for review

Leela can prepare the work and supporting evidence for your review and decision.

Leela can compile the rule-level figures each month, flag rules that are silent or noisy and typologies with no rule, and draft the report and the calibration memo for the Officer.

Applies

Tell Leela about your company to see whether this applies.

Status
Setup needed

Tell Leela how you handle it today, or hand it over: see what’s next.

What’s next?