Governance & Program Info
Fraud Investigation Orchestration — Governance
Cross-builder institution context and per-item ownership, due dates, status, and next actions for the governance-relevant checklist items in this builder.
Institution context
Program info
Applies across every builder in the app. Stored locally; nothing leaves the browser.
Checklist governance
Items (0 of 12 marked complete)
Annotate ownership, due date, status, and next action. Items on the left come from the builder's governance / compliance phases.
05 · Governance & Compliance
Confirm agent workflow satisfies 31 CFR 1020.320 filing timeline
Initial SAR within 30 calendar days of detection; continuing SARs every 90 days for ongoing activity. Agent must reliably close cases within this window.
05 · Governance & Compliance
Enforce 31 USC 5318(g) SAR confidentiality
SAR existence and contents cannot be disclosed outside narrow statutory channels. Agent logs and training data must respect 5318(g).
05 · Governance & Compliance
Track FinCEN guidance and typology updates
FinCEN publishes advisories and typology guidance regularly — agent knowledge base and narrative drafter must refresh against these.
05 · Governance & Compliance
Document the agent as an AML compliance tool in BSA/AML program
The bank's BSA/AML program document must name the investigation agent as a compliance tool with defined role, oversight, and human-approval structure.
05 · Governance & Compliance
SR 11-7 documentation for scoring components
The triage classifier, typology classifier, and graph model are models under SR 11-7 — full documentation, independent validation, ongoing monitoring.
05 · Governance & Compliance
Independent validation of the agentic workflow end-to-end
Second-line or external validation of the agent's investigation quality, grounding, and SAR draft acceptance rate.
05 · Governance & Compliance
Ongoing performance monitoring plan
KPIs for agent step latency, grounding rate, SAR acceptance rate, and filing timeliness. Alerts on degradation.
05 · Governance & Compliance
SEC Rule 17a-4 / FINRA-compliant audit trail
$600M+ in SEC recordkeeping penalties were levied across 70+ institutions in FY2024 — AI-assisted investigation requires the same recordkeeping rigor as human investigation.
05 · Governance & Compliance
Capture agent decision provenance per case
Model version, prompt version, retrieved documents, tool-call history, and full reasoning trace stored per case for audit.
05 · Governance & Compliance
Enforcement intelligence: monitor FinCEN / FCA / OCC signals
Fenergo reports 31% YoY enforcement growth H1 2024; global compliance spend reached $190B (Celent 2024). Track precedents affecting your agent deployment.
05 · Governance & Compliance
Cyber-SAR and check-fraud SAR pattern readiness
Cyber-SARs grew 30% YoY in 2025; check-fraud SARs hit 7.46% of bank SARs. Agent must handle these emerging typologies.
05 · Governance & Compliance
Board-level reporting on agentic AML posture
SAR filing volume, timeliness, and agent-assisted share reported at board risk committee — not only at ops dashboards.