Financial Crime Operations
Agentic KYC, AML, fraud, and sanctions casework with policy-bound investigation, human adjudication, and audit evidence.
Purpose
Help financial-crime teams move from alert queues to evidence-bound case decisions. A conforming runtime can coordinate investigation agents that gather facts, compare policy, draft narratives, and recommend disposition while keeping policy- or regulation-designated decisions with accountable humans.
The roles/gates below are illustrative institution policy, not universal AML/sanctions rules or regulatory approval. An accountable domain owner determines current jurisdiction, reporting, confidentiality and retention duties. FATF’s digital-transformation research is context, not certification of this workflow. Admit exact enterprise and any required durable/high-assurance profiles with actual features and current deployment evidence; the repository does not run case systems or filings.
Why this is agentic-first
KYC, AML, sanctions, and fraud workflows are not single prompts. They require multiple evidence sources, policy interpretation, identity resolution, adverse-media review, transaction analysis, case writing, and supervisory approval. McKinsey describes agentic AI in financial-crime contexts for client onboarding, KYC refreshes, transaction monitoring, sanctions, and fraud investigations from alert to case closure.
ContextOS is useful because every case must explain why the agent touched each source, which rule fired, who approved the disposition, and which evidence snapshot supports the decision.
Context Pack
| Layer | Required entries |
|---|---|
decision_layer.decision_specs[] | fincrime.alert.triage, fincrime.kyc.refresh, fincrime.case.disposition, fincrime.report.file |
policy_layer.policy_bundles[] | AML policy, sanctions policy, fraud policy, customer risk policy, data-retention policy |
policy_layer.approval_gates[] | GATE_INVESTIGATOR_REVIEW, GATE_MLRO_APPROVAL, GATE_REGULATORY_REPORT |
tooling_layer.adapter_registry[] | adp_corebanking.lookup, adp_kyc.fetch, adp_txn.analyze, adp_sanctions.screen, adp_case.update, adp_report.file |
memory_layer.memory_policy.write_classes_allowed | evidence_link, correction, decision_outcome; case-pattern labels are domain content, not additional canonical write classes |
evaluation_layer.eval_targets[] | P/U/L/S/E targets; false negatives, escalation quality, narrative completeness and review acceptance are domain-suite metrics |
Agent roles
| Agent | Responsibility | Boundary |
|---|---|---|
| Alert Triage Agent | Clusters alerts and resolves customer, account, and transaction identity. | Cannot close cases. |
| Evidence Agent | Fetches KYC, sanctions, transaction, and adverse-media evidence. | Read-only except case notes. |
| Policy Agent | Maps evidence to policy rules and required case fields. | Cannot override policy. |
| Narrative Agent | Drafts an evidence-linked case summary, rationale and timeline for qualified review. | Draft only; fluency is not filing validity. |
| Supervisor Agent | Checks completeness, contradictions, and approval requirements. | Can block disposition. |
Execution flow
invokeAgentarrives withintent=fincrime.investigate, alert IDs, jurisdiction, customer ID, and queue priority.- Trusted admission resolves current policy/source/jurisdiction/retention/schema pins and exact controls; the compiler consumes supplied structured inputs and stops on applicable policy-expression errors.
- Alert Triage Agent clusters duplicate or related alerts.
- Evidence Agent gathers account, KYC, transaction, sanctions, and adverse-media evidence.
- Policy Agent evaluates rule matches and required fields.
- Narrative Agent drafts a case package with citations and gaps.
- Supervisor Agent verifies evidence completeness and conflict status.
- Low-risk false positives can be recommended for human batch approval. Suspicious activity, sanctions hits, or regulatory filings require named approval.
- The Gateway validates complete stored action/payload/destination/pin approval, eligible current roles/quorum and atomic redemption, plus current scope/revocation, actual boundary/data routes and aggregate reservation before owned operation dispatch.
- The implementing runtime emits a
DecisionRecordwithdecision_key="fincrime.case.disposition".
Separate recommendation, authorized disposition and verified filing/case-system postconditions. A lost filing acknowledgement leaves an unknown stable operation and uncertain reservation; follow the institution/provider reconciliation path rather than submitting again from a timeout or expired key. Checkpoints preserve original case/release interpretation, current ownership/fencing and shared budget/deadline; delayed approval does not refresh authority. Protected correction/withdrawal is a new independently governed operation.
Verify actual purpose, source classification, recipient/model processor, residency, access and retention for customer records, adverse-media content, drafts, telemetry, caches and exports. A reviewer agent or generic consent flag cannot authorize disclosure. Keep personal/work and tenant scopes separate, govern derivative memory proposals/copies and preserve required independent review. Execution Contract and Conformance define the runtime/evidence limits.
Decision gates
| Gate | Trigger | Required evidence |
|---|---|---|
GATE_INVESTIGATOR_REVIEW | Any case closure, escalation, or customer risk-rating change. | alert cluster, rule matches, evidence refs, narrative |
GATE_MLRO_APPROVAL | Suspicious activity recommendation or high-risk jurisdiction. | full case package, policy citations, reviewer notes |
GATE_REGULATORY_REPORT | Filing, correction, or withdrawal of regulated report. | filing payload, jurisdiction rule, approval chain |
Failure modes
- Identity collision - verify authoritative source identifiers and CEID-linked evidence for customer/account/transaction relationships. A SID or similarity score is a retrieval feature, not proof of identity or authority.
- Source conflict - contradictory KYC or sanctions data triggers
escalateinstead of disposition. - Policy version mismatch - admission validates the supported pinned policy set and interpretation; the compiler does not implement a universal version resolver. Resume under a changed set requires explicit migration/reauthorization.
- Narrative without evidence - Supervisor blocks case updates when claims lack
evidence_refs. - Over-automation risk - high-risk decisions stay as recommendations until human approval.
Metrics
- Case package completeness.
- False-positive/false-negative performance on declared labeled, stratified cases, with sampling, unknown outcomes and review limits disclosed rather than assuming all live misses are observable.
- Investigator acceptance rate.
- Time from alert to first decision.
- Regulatory filing defect rate.
- Number of policy gaps discovered through operator correction.
Research signals
- McKinsey describes agentic AI across KYC, transaction monitoring, sanctions, and fraud investigations.
- McKinsey’s corporate credit process article describes layered agents for analysis, controls, synthesis, and human validation.
- Gartner’s guardian-agent research reinforces the need for automated oversight as agent power increases.