Anti-Money Laundering (AML)
The Anti-Money Laundering (AML) Workflow is a structured process designed to help users identify, investigate, and resolve potential financial crimes. It begins with the creation of a case triggered by suspicious activity such as unusual transactions or customer behavior based on predefined risk indicators and scoring models.
Table of Contents
Each case progresses through a series of Workflow Stages. These stages are tailored to the user’s role and permissions, ensuring secure and relevant access throughout the process.
Depending on the outcome of the investigation, the workflow may conclude with:
- Submission of a Suspicious Activity Report (SAR) or a Currency Transaction Report (CTR) to the Financial Crimes Enforcement Network (FinCEN), or
- Case closure if no risk exposure is identified.
AML Workflow Stages
The AML Workflow consists of four key stages:
- Screening – Initial review of alerts or flagged activity.
- Investigation – Detailed analysis of the Case, including evidence gathering and risk assessment.
- Review – Managerial review of findings, leading to approval of closure or SAR submission.
- Closed – Final stage where the Case is archived. Only limited actions (e.g., commenting) are permitted.
The following diagram provides a visual summary of the AML Workflow.
Stage Transition Actions & Dialogues
Users can transition a Case between Workflow Stages using the available actions located in the top-right corner of the Case List/Details page.
Stage Transition Actions |
Stage Availability |
Description |
Permissions |
---|---|---|---|
Assign |
Screening |
Allows the manager user to assign the Case directly to a user and transition the Case into the Investigation Stage. |
Manager User Group |
Re-Assign |
Investigation, Review |
Allows the manager user to re-assign the Case directly to another user without changing the Stage. |
Manager User Group |
Close |
Investigation |
Allows the investigator user to send the Case to Review Stage with the proposed resolution outcome of Closed. |
Investigator User Group |
Request SAR Review |
Investigation |
Only available if a Case has a SAR. Allows the Investigator to transition the Case to Review Stage and re-assign to a manager user for review. |
Investigator User Group |
Return to Investigator |
Review |
Allows the manager review to transition the Case back to Investigation Stage and re-assign to the Investigator user. |
Manager User Group QA User Group |
Approve Closure |
Review |
Allows the manager user to transition the Case the Closed Stage with a resolution outcome of Closed. |
Manager User Group QA User Group |
Approve SAR |
Review |
Allows the manager user to transition the Case to Closed Stage with the resolution outcome of Closed with SAR. |
Manager User Group |
Re-Open |
Closed |
Re-Open a Cases to an available Stage and assign it to a user. |
Manager User Group
|
In-Stage Actions
These are the actions that the user can perform within the Case that do not result in a Stage Transition of the Case within the Workflow. There are some variations depending on Case Type.
The table below covers the set of in-stage actions available within the AML Workflow.
In Stage Action |
Availability & Notes |
---|
In Stage Action |
Availability & Notes |
---|---|
Re-Assign |
Investigation, Review |
Re-Name the Case |
All active stages |
Link a Case to another Case |
All active stages |
Unlink a Case from another Case |
All active stages |
Promote a Linked party to be a subject |
All active stages |
Remove a subject |
All active stages |
Add a Linked party to a Case |
All active stages |
Return a subject to be a Linked party |
All active stages |
Remove a Linked party |
All active stages |
Add an Attachment - This should be possible in the Review Stage even where there is a SAR. |
Review Stage (even when a SAR is present) |
Download an Attachment -This should be possible in the Review Stage even where there is a SAR. |
Review Stage (even when a SAR is present) |
Remove an Attachment -This should be possible in the Review Stage even where there is a SAR. |
Review Stage (even when a SAR is present) |
Add a Comment -This should be possible in the Review Stage even where there is a SAR. Comments are the only In-Stage action that is possible in the Closed Stage. |
Review Stage (even when a SAR is present); Closed Stage (only permitted action) |
Remove a Comment -This should be possible in the Review Stage even where there is a SAR. Comments are the only In-Stage action that is possible in the Closed Stage. |
Review Stage (even when a SAR is present); Closed Stage (only permitted action) |
Edit Narrative -This should be possible in the Review Stage even where there is a SAR. |
Review Stage (even when a SAR is present) |
Edit CTR Content/Fields |
CTR Case Types only |
Generate a SAR |
Not available in Screening Stage |
Edit SAR Content/Fields -There is no SAR in a CTR Case Type. If the user thinks a SAR is necessary then they need to use the unusual activity Form CTA to raise a Case of Type AML. |
Not applicable in CTR Case Types; use “Unusual Activity” Form CTA to raise AML Case |
Clone a Graph |
All active stages |
Remove a Graph |
All active stages |
Open the Graph in a new tab |
All active stages |
Rename the Graph |
All active stages |
Search the Case History |
All active stages |
Filter the Case History |
All active stages |
Share a Case |
All active stages |
Export a SAR to file |
Not available in Screening Stage |
