Practice area
AML & sanctions.
AML and sanctions work calibrated to your institution's actual risk profile. False positive reduction, investigation efficiency, and model confidence — built in, not bolted on.
An AML program built around your business, not a standard template.
Periodic tuning is standard practice. The harder question is whether the model is actually working for the business — reducing false positives, surfacing genuine risk, and keeping investigation resources focused where exposure is real. Most tuning exercises produce a report. Few produce a model the institution can explain, defend, and operate with confidence. That is true even when outside consultants ran the study.
Our work covers independent program reviews, look-backs, tuning studies (threshold and rule optimization with statistical evidence), and ongoing model validation under SR 11-7 for institutions that have moved to ML-based detection.
We have built and overseen these programs as practitioners. The analysis we produce shows the math — and explains what it means for the business.
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 | Deliverable |
|---|---|
| Data & scope | Transaction data pulled, alert history reviewed, scope of tuning agreed. |
| Statistical study | Below-the-line and above-the-line testing; threshold sensitivity analysis. |
| Recommendations | New thresholds, retired rules, new typologies, governance changes. |
| Documentation | Tuning report, methodology memo, executive briefing for the BSA officer and the committee. |