Look-back reviews
Monitoring missed something. Now every record in the period gets looked at again.
A look-back re-reviews historical transactions and alerts after a monitoring failure. We re-test every record in scope and document the result for each one, without the months of a large review team.
Your problem
A deadline, a regulator watching, and a period nobody reviewed properly
- A regulator, your sponsor bank or your own testing has found that transaction monitoring missed activity for a period of time.
- Every transaction and alert in that period now has to be reviewed again, and the result has to stand up to the party that asked for it.
- Look-backs are usually staffed as large review teams working through alerts by hand, which is why they take months and cost what they do.
What you get
A disposition for every record, and a report that closes the matter
- A signed look-back report with the method, the scope and the results.
- A disposition for every record in scope, with the evidence behind it, including the ones that needed no action.
- A list of reports that should have been filed, with the facts for each.
- Findings on the monitoring failure itself, cited and priced, so it doesn't happen again.
How we do it
Agree the method, re-run everything, judge what needs judgment
- We agree the scope, the period and the method with you, and with the regulator or bank where they set the terms.
- The engine re-runs monitoring logic across every transaction in the period and re-reviews every alert, historical and newly generated.
- Records that need judgment go to a practitioner, with the evidence for each one assembled.
- The disposition of every record is documented.
Where a regulator requires the reviewer to be approved in advance, that approval is part of the scope.
How the work is done
The audit you already buy, performed by an engine.
- Every record testedControls are tested against the full population of accounts and transactions, not a sample of twenty-five.
- Every requirement citedEach requirement the work runs against is cited to the rule it comes from, with the facts behind it labelled.
- Findings pricedFindings arrive priced in dollars, so remediation is ordered by what each gap is worth.
- A signed reportThe report is signed, and any reader can check that nothing in it changed after signing.
Pricing
Quoted on the volume, not the headcount
This replaces a look-back engagement staffed by a large consulting team.
Price: Priced at scoping, quoted on the volume in scope. How pricing works
The published method
How this is normally done
The regulator's and the standard-setter's own method for this work, explained in plain English and cited to the source. We have nothing to hide about how we do it: check our process against it.
- ReferenceAML Look-Back Reviews: Transaction and SAR Look-Backs ExplainedWhat triggers a transaction or SAR look-back, how the period and population are set, re-running monitoring logic versus re-reviewing alerts, reviewer independence, and the deliverables.
- ReferenceTransaction Monitoring: How AML Monitoring Programs WorkWhat transaction monitoring is, the parts of a monitoring program, the path from alert to SAR, tuning and threshold testing, model risk guidance, and NYDFS Part 504.
- Field GuideHow to Write a SAR Narrative That Holds UpThe five W's and how, the anatomy of a strong narrative, a before/after example, the mistakes that draw scrutiny, and a filing-ready checklist.
What happens next
Three steps from here.
- 01
A confidential call
What was found, who found it, the period in question and any terms already set.
- 02
A written method
Scope, period, method and timeline, in a form you can put in front of the party that asked for the review.
- 03
The review and the report
Every record re-tested, a practitioner on the ones that need judgment, and a signed report.