Practice area · 05/08
AML & sanctions.
Program reviews, look-backs, and tuning for transaction monitoring systems. Calibrated for the regulator who will read your next exam.
Program reviews, look-backs, and tuning for transaction monitoring systems. Calibrated for the regulator who will read your next exam.
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 'is the program designed for the institution's risk profile' assessment), 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.
Risk assessment, governance, controls, training, and reporting against BSA/AML expectations.
Reprocessing transactions for a defined window — typically driven by an MRA or consent order.
Below-the-line testing, above-the-line testing, alert-to-SAR conversion analysis.
List management, name/transaction screening calibration, false-positive analysis.
New typologies (crypto on-ramps, layering through fintech rails), retired typologies, calibration.
Risk rating models, periodic refresh cadences, high-risk customer governance.
Transaction data pulled, alert history reviewed, scope of tuning agreed.
Below-the-line and above-the-line testing; threshold sensitivity analysis.
New thresholds, retired rules, new typologies, governance changes.
Tuning report, methodology memo, executive briefing for the BSA officer and the committee.
Enterprise Risk · Board Advisory
Patricio has built and overseen BSA/AML and sanctions programs as a senior risk and audit executive in financial services, carrying them through examination by every regulator that examines for BSA. Member of The National Executive Roundtable.
We do not file Suspicious Activity Reports on behalf of our clients, and we do not act as a BSA Officer of record. That role belongs inside the institution.