The CAIBots KYC/AML Agentic AI platform is a continuously running compliance intelligence layer that operates across three simultaneous time horizons: new customer onboarding (CDD/EDD), perpetual KYC monitoring, and real-time transaction screening. Seven specialized AI sub-agents run in parallel against five peer data source tools. Agent pipeline runtime: <10 seconds end-to-end.
Mandatory HITL — Non-Negotiable
Every critical action is gated behind a mandatory human-in-the-loop checkpoint. The system cannot auto-file a SAR, auto-exit a customer, or resolve a sanctions hit without an authorized human decision. The agent prepares — the BSA Officer decides.
Capability
Status
Implementation Notes
Retail / Commercial / Institutional CDD/EDD
Covered
All three DD levels. Correct regulatory routing. 25%/10% UBO thresholds enforced. FinCEN CDD Rule 31 C.F.R. §1010.230 compliant. Automatic tier assignment — SDD (<30), CDD (30–65), EDD (>65 or any PEP/sanction adjacency).
Perpetual KYC — Event-Driven Monitoring
Covered
Score drift >15pts triggers automated refresh with no analyst request. Replaces calendar-based periodic review entirely. 60–70% pKYC workload reduction vs. traditional scheduled review programs.
FATF 52-Typology Transaction Monitoring
Covered
All 52 typologies: structuring, layering, TBML, bulk cash, MSB patterns, hawala (core). Actimize/Verafin bidirectional integration. For structuring: calculates total avoided CTR reporting amount and maps full counterparty network.
OFAC / EU / UN / HMT Sanctions Screening
Covered
Real-time — not batch. Fuzzy name matching handles transliteration variants and name permutations. 2-hop PEP proximity screening. SDN cache TTL 1 hour — system never relies on stale list data for more than 60 minutes. Immediate blocking on any SDN hit.
SAR / CTR Filing Automation
Covered
Mandatory HITL approval gates all filings. Direct FinCEN BSA E-Filing post-approval. Agent never auto-files. BSA Officer is always the filer of record. 30-day SAR clock tracked with T-14 and T-7 escalation alerts. CTR auto-populated on qualifying cash events within 15 calendar days. OFAC blocking report filed within 10 business days of confirmed SDN hit.
FinCEN 314(a) / 314(b)
Covered
14-day window tracking. See Scenario 07 — live 314(a) batch match with CTA 2024 BOI non-compliance and circular UBO detection. Automated search executed on every 314(a) batch receipt. 5-year lookback applied automatically. HITL gate for BSA Officer response decision. 314(b) voluntary sharing referral generated when Knowledge Graph identifies cross-institution patterns.
Beneficial Ownership & CTA 2024 BOI
Covered
Full UBO traversal to natural persons. Shell company, circular ownership, and nominee structure detection. FinCEN BOI registry cross-reference on all commercial entity onboarding. CTA 2024 discrepancy flags triggered automatically when filed BOI diverges from detected ownership.
Correspondent Banking Risk
Covered
See Scenario 06 — live correspondent banking EDD with FFIEC Chapter 13. SWIFT path risk assessment, nested correspondent chain analysis, HIFCA designation checking, de-risking workflow with advisory HITL for significant relationships. Multi-hop correspondent risk propagated through Knowledge Graph.
PEP Screening & Adverse Media NLP
Covered
Dow Jones, Refinitiv World-Check, LexisNexis. 300+ monitored sources. 0–100 adverse media score with network propagation — UBO adverse media contaminates related-party network risk scores.
SR 11-7 Model Governance Framework
Covered
Back-testing (Gini >0.65 target), material change taxonomy with 7 defined change types, independent validation requirement framework. Full MRM documentation package included with every production deployment.
GDPR & Data Residency Architecture
Covered
PII boundary design — no PII in LLM prompts. DPIA template provided. EU regional deployment available (Pinecone Frankfurt, Neo4j AuraDB EU). Anthropic EU DPA with Standard Contractual Clauses available.
BSA Lookback Review Automation
Phase 2
Consent order lookback requires a distinct retroactive pipeline with different trigger logic and historical data traversal. Architecturally designed — not yet built. Estimated 8–12 weeks to production.
Real-Time Payments (FedNow / RTP)
Phase 2
Sub-100ms latency screening not yet architected. Agent-only pipeline: <10 seconds. Full CDD case (including HITL): <90 seconds end-to-end. Real-time payment rail screening requires dedicated low-latency inference path. Estimated 10–14 week build.
Capital Markets Surveillance
Out of Scope
Layering, spoofing, wash trading, MiFID II MAR — market abuse monitoring is a separate product domain from BSA/AML. Extension path available: 12–16 weeks as a parallel development track.
