Executive Decision Pack

SAMPLE-02 · AI-assisted AML transaction monitoring
Generated 2026-10-31 14:52 UTC · Owner: Marcus O'Brien · Sponsor: Head of Financial Crime

DECISION
APPROVE WITH CONDITIONS
Trust Score: 58/100 · ARA residual: Medium · CALIBRE band: High (GII 63.75) · Evidence coverage: 85%

Scenario

A Tier-2 Australian bank proposes to replace its rules-based AML transaction-monitoring engine with an LLM-based agent that reads payment memos, customer notes and adverse-media results to score suspicious-matter reports. The agent will draft the SMR narrative and auto-lodge to AUSTRAC once a compliance analyst clicks approve. Model hosted on a US cloud region.

Decision narrative

Initiative SAMPLE-02 (AI-assisted AML monitoring) is assessed at ARA overall-residual Medium, CALIBRE band High (GII 63.75/100). The analyst-in-the-loop design materially reduces risk versus fully autonomous SMR lodgement.

The main remaining risks are (1) hallucinated content in SMR narratives, which the grounding-verification control directly mitigates, and (2) cross-border data transfer, which requires an APP 8 compliant contract before go-live.

Approve with conditions. Do not go live until the four listed conditions are satisfied and evidence uploaded against each.

Top risks driving the decision

  1. R-RG-01 AUSTRAC SMR content integrity
  2. T-AI-02 Hallucinated transaction detail in SMR
  3. R-DA-01 Cross-border transfer of customer data

Conditions for approval

  1. Analyst attests every SMR before lodgement
  2. Grounding verification live in production
  3. APP 8 compliant cross-border contract executed
  4. False-positive monitoring dashboard operational

Evidence attached

None yet attached.

Remaining evidence gaps

None outstanding.

Actions and owners

IDActionOwner rolePriorityStatus
SAMPLE-02-A-01Implement Analyst approval gate before AUSTRAC lodgementHead of Financial CrimeHighOpen
SAMPLE-02-A-02Implement Grounding verificationAI Product OwnerHighOpen
SAMPLE-02-A-03Execute Cross-border data-transfer contract with vendorLegal / ProcurementHighOpen
SAMPLE-02-A-04Establish False-positive monitoring dashboardCompliance AnalyticsMediumOpen
SAMPLE-02-A-05Update customer collection notice for cross-border transferPrivacy OfficeMediumOpen
Approved by (name and role):

____________________________
Signature:

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Date:

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Audit trail: full machine-readable finding history, model IDs, timestamps, and evidence citations are stored in the Governance Fabric under initiative SAMPLE-02. Regenerate this pack at any time from the initiative page.