Governance & Program Info
AML / Sanctions Screening — 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.
06 · Explainability & Governance
Implement SHAP for match score attribution
Which features drove the risk score above threshold? SHAP values provide the per-feature contribution for each alert.
06 · Explainability & Governance
Generate match rationale narrative per alert
Every alert must include: match score, matched list entry, matching fields (name, DOB, nationality), and confidence level — in human-readable form for analysts.
06 · Explainability & Governance
Implement alert disposition audit trail
Every analyst decision (true match / false positive / escalate) must be logged with timestamp, analyst ID, and rationale. Required for exam readiness.
06 · Explainability & Governance
Generate graph visualization for network alerts
For network/typology alerts, provide a visual account relationship graph showing the flagged transaction pattern — required for analyst adjudication and SAR narrative.
06 · Explainability & Governance
Implement threshold tuning audit log
Any change to match thresholds or scoring weights must be documented with business justification and validation evidence. Examiners frequently challenge threshold decisions.
06 · Explainability & Governance
Document model purpose, scope, and known limitations
What the model screens for, what it cannot detect, and known false negative exposure areas. Required model risk management documentation.
06 · Explainability & Governance
Conduct independent model validation (SR 11-7 / SS1/23)
For US bank holding companies: SR 11-7. For UK firms: PRA/FCA SS1/23. Third-party or independent internal team validates model assumptions and performance.
06 · Explainability & Governance
Maintain Written BSA/AML Compliance Program documentation
FinCEN requires a documented, board-approved BSA/AML program. The screening model must be referenced in the program document.
06 · Explainability & Governance
Define SAR filing workflow and automation
What triggers a SAR? Who approves? What is the 30-day filing SLA from detection? Automate where possible but maintain human review gate.
06 · Explainability & Governance
Establish training and certification program for AML analysts
CAMS certification or equivalent. Analysts must understand model outputs and maintain disposition quality. Documented training is an exam requirement.
06 · Explainability & Governance
Conduct annual BSA/AML model risk assessment
Annually evaluate: list coverage, model performance, emerging typologies not covered, false negative exposure. Document findings and remediation plans.
06 · Explainability & Governance
Assess and document model fairness / disparate impact risk
AML models with demographic proxies can produce discriminatory false positive rates. Conduct fairness audit and document findings for exam readiness.