KYC / AML Agentic AI — 90-Day Pilot Structure

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Confidential · For Authorized Personnel Only . CAIBots © 2022–2026
90-Day Production Pilot · Structure & Terms
KYC / AML
Agentic AI
Pilot Structure & Terms
5 Phases · 13 Weeks 16 UAT Scenarios Fixed Pilot Fee · No Lock-In SR 11-7 Documentation Included
What Success Looks Like
✓SDD auto-clear rate >70% eligible retail
✓EDD review time <55 min mean (from 4.5 hrs)
✓CDD review time <12 min mean (from 90 min)
✓SAR quality: >85% rated B-or-better
✓OFAC false negative rate: 0.00%
✓BSA Officers certified and processing live cases
✓SR 11-7 model documentation complete
What You Walk Away With
✓Fully calibrated AI KYC/AML system tuned to your risk appetite
✓Complete SR 11-7 model documentation package
✓Validated AML platform integration spec
✓Quantified ROI in your own data
✓If you decide not to proceed: you keep all documentation, calibration data, and the integration spec
✓No lock-in. No penalty.
Confidential · For Authorized Personnel Only CAIBots © 2022–2026 · caibots.com contact​@caibots​.com · +1 (609) 721-2815 · Princeton, NJ
Confidential · For Authorized Personnel Only
01
Pilot Structure

5 Phases · 13 Weeks

Each phase has a defined deliverable and success gate — no phase proceeds without the prior gate being met
1
Architecture Scoping
Weeks 1–2
CAIBots + Your AML Tech Lead
Integration spec mapped to your AML platform (Actimize/Verafin/Fiserv). Data readiness assessment completed against all five source tool requirements. Risk appetite calibration plan drafted with BSA Officer. External API credential inventory confirmed.
Go/No-Go Gate · Before Any Infrastructure Spend
2
Build & Calibrate
Weeks 3–6
CAIBots Engineers + BSA Officer
API connections established with the institution's licensed feeds and credentials (identity, sanctions, adverse media, ownership) — vaulted institution-side. Regulatory corpus loaded into Pinecone vector store (FinCEN CDD Rule, FFIEC Manual, 52-pattern typology library (FATF/FinCEN-curated), institution's BSA policy). Governed retrieval calibration on your 500+ closed KYC/AML cases — SAR narrative calibrated to your institution's filing voice via a curated, versioned corpus under SR 11-7 change control. No institution data is used to train or fine-tune model weights. Risk dimension weights and tier thresholds set with BSA Officer sign-off. All 16 UAT scenarios executed and passed.
Deliverable: BSA Officer Sign-Off on Risk Thresholds
3
Parallel Run
Weeks 7–10
Both Teams · Shadow Mode
CAIBots runs in shadow against your live case volume — your current process is unchanged. Weekly comparison reports: agent risk scores vs. analyst risk scores, SAR draft quality ratings (A/B/C/D), false negative tracking. Target: <10% material disagreement rate (>15-point score difference), false negative rate <2%.
Deliverable: 4-Week Parallel Run Report
4
Staged Go-Live
Weeks 11–12
BSA Officer Gates Each Stage
Staged cutover by case type: SDD auto-clear (Week 11) → Standard CDD (Week 11) → EDD/SAR cases (Week 12). Your existing process remains as a fallback at every stage. BSA Officer must sign off before each stage advances. If any metric falls below target, stage is paused and recalibration cycle initiates before proceeding.
Existing Process Remains Live Fallback at Every Stage
5
Measure & Decide
Week 13
Both Teams + CCO
Pilot results report delivered: analyst hours saved, SDD auto-clear rate achieved, EDD/CDD review time reduction, SAR draft quality scores — your data, not industry benchmarks. Institution decides independently: expand to additional business lines, full production deployment, or conclude pilot. All documentation, calibration data, and integration spec is yours regardless of decision.
Your Decision · No Obligation to Continue · No Penalty to Exit
Pilot Investment
Fixed pilot fee — contact for pricing. Pilot investment typically ranges from $45K–$95K depending on case volume, integration complexity, and calibration depth. Covers all engineering, retrieval-index building on your closed cases, UAT support, SR 11-7 model governance documentation, and 90-day results report. No infrastructure spend required. No penalty to exit. Covers all engineering, calibration, in-weights retrieval-index building on your closed cases, UAT support, parallel run analysis, and the pilot results report. No infrastructure cost during pilot. Runs on CAIBots cloud. Institution provides API credentials and read access.
All Engineering Retrieval Calibration on Your Cases UAT Support SR 11-7 Docs Pilot Results Report No Infrastructure Cost
$150K–$300K Capgemini pKYC scoping alone — before a line of code is written
Confidential · For Authorized Personnel Only
02
User Acceptance Testing

12 Required UAT Scenarios

All 16 must pass before go-live authorization is granted · Evaluated by the BSA Officer with live production data connections
#
Test Scenario
Expected Outcome
Pass Criteria
U1
Clean retail onboarding
SDD Auto-Clear
Score <30, no adverse flags, CDD file generated, no analyst queue entry
U2
PEP-adjacent commercial account
EDD Mandatory
Score >65, PEP proximity flagged, EDD memo generated, HITL gate triggered in workbench
U3
Structuring — 47 txns $9,800–$9,950
SAR Obligation
FATF T-04 matched, SAR draft with 31 U.S.C. §5324 citation, 30-day clock, HITL triggered
U4
OFAC SDN exact match
Immediate Block
Block within 3 seconds, OFAC hit logged, HITL triggered for BSA Officer, 10-day clock initiated
U5
OFAC fuzzy match — transliteration variant
Fuzzy Match Alert
Match surfaced with confidence score, BSA Officer HITL gate triggered for resolution decision
U6
3-layer shell company (BVI→UAE→US)
EDD + UBO Flag
Full UBO chain traversed, circular check passed, PEP network screening on all UBO nodes
U7
FinCEN 314(a) batch match
Match in 14-day Window
Match surfaced in workbench, 14-day clock shown, BSA Officer HITL gate for response decision
U8
Adverse media hit on related party
Network Risk Elevation
Score propagated from related entity, customer score elevated, EDD review triggered
U9
pKYC score drift >15 points
Auto-Triggered Refresh
Drift detected, automated trigger fired, investigation dispatched without any scheduled review or analyst request
U10
SAR narrative quality — MSB structuring
File-Ready Draft
BSA Officer rates draft B or higher — file-ready with at most minor edits. Narrative matches institution's filing voice.
U11
Correspondent banking — FATF grey jurisdiction + nested SWIFT chain
FFIEC Ch.13 EDD
FFIEC Ch.13 EDD memo generated with de-risk disposition options. SWIFT path risk assessed. BVI UBO chain traversed. BSA Officer HITL gate triggered for relationship authorization decision.
U12
FinCEN 314(a) match + BOI non-compliance (foreign reporting co. — 2025 rule) + circular ownership
SAR + 314(a) Response
314(a) response drafted within 14-day deadline. BOI non-compliance flagged with FinCEN referral pathway. Circular ownership structure detected. SAR draft generated — 30-day clock started. Four HITL gates triggered. BSA Officer approval required before any filing.
U13
OFAC dual sign-off + write-failure compensation
BLOCK · Dual + Rollback
Sanctions Officer + BSA Officer both required (single-signer action refused). Simulated case-management write failure triggers compensation rollback, then idempotent retry succeeds with no duplicate. Blocking-report task opens on the 10-business-day clock (31 C.F.R. §501.603).
U14
SAR dual review governance
Dual Review Enforced
Recommendation stays sealed until analyst reveals (reveal time logged). Rationale under 15 characters refused. KYC Analyst + BSA Officer signatures both required before any SAR action. Confidentiality banner present (31 U.S.C. §5318(g)(2)).
U15
314(b) registration halt — negative test
Sharing Refused
Request from an unregistered institution halts BEFORE any case data is accessed. With registration verified, response contains transaction facts only — zero reference to the existence or non-existence of any SAR.
U16
De-risking committee enforcement
3 Signatures Required
Exit action with two of three signatures is refused and logged. All three (BSA Officer + CCO + Head of Financial Crimes) with rationale → executes. Fair-access individualized basis documented; exit letter discloses nothing about any filing.
03
Go-Live Authorization

Required Signatures

No sign-off · No production traffic · All signatures required before any live case processing
BSA Officer (Designated)
Date: ___________________
Required
Chief Compliance Officer
Date: ___________________
Required
AML Technology Lead
Date: ___________________
Required
CISO / Information Security
Date: ___________________
Required
Data Governance Officer
Date: ___________________
Required
Legal / Regulatory Counsel
Date: ___________________
Strongly Rec.
Book the Architecture Call

In a 30-minute architecture session we map this pipeline to your AML platform, data infrastructure, and compliance team workflow. A scoped 90-day production pilot can begin within two weeks of that session.

contact​@caibots​.com · +1 (609) 721-2815 · caibots.com · Princeton, NJ

Pilot Scope · Aligned to the Live Estate
The pilot exercises the same eleven governed lanes demonstrated in the live estate — from SDD auto-clear through SAR filing, OFAC block AND documented release, 314(a)/(b), correspondent, pKYC, de-risking, and TM-alert false-positive disposition — under a policy pack your compliance team versions and fingerprints. Diligence-ready from day one: the public Coverage Benchmark & Gap Register states exactly what is and is not exercised, and every pilot session ships with the hash-chained ledger, client-side ⛨ verification, and the ⬇ Case Binder your examiners can replay offline. Success criteria are defined against the projections of record per lane — not against demo-compressed clocks.