Insights
Notes from the alert queue
Short, sourced pieces on the rules that shape alert review and the controls an AI agent needs to be allowed near it. Every regulatory claim links to the primary document. Written by the founder, not a content team.
SR 26-2 left agentic AI out of scope. Here is what banks should do instead
The April 2026 model risk guidance covers statistical models and non-generative AI. For an agent that triages alerts, the bank has to write its own control set. This is a practical one.
Structuring that rules miss: evasion indicators worth teaching an agent
A threshold rule finds cash deposits between $8,000 and $10,000. It cannot tell a convenience store's normal week from a customer who asked a teller how to avoid a report. These indicators can.
What FinCEN's October 2025 SAR FAQs change for alert reviews
Four answers from FinCEN and the four federal banking regulators. None of them changes the law. Three of them change how much effort an L1 queue should spend on alerts that were never going to become SARs.
Figures used across the site, with their sources and the assumptions behind modeled numbers, are on Sources and assumptions.