An example of AML transaction monitoring as a governed process: agents do the 11 steps, and a person signs the gate before anything irreversible happens. Download it, import it into your workspace, and adapt it to your systems.
minctrl.process/v1 · hash ebae017ef8af…b945
Financial-crime compliance is a $61B labor sink of manual screening and alert triage — and a missed SAR or sanctions hit is personal liability for the BSA Officer. Onboarding, screening and alert triage run straight-through with a documented rationale; only genuine risk reaches the BSA Officer, who signs every SAR and high-risk approval.
Filing a SAR with FinCEN is irreversible and legally consequential, so a compliance officer signs the SAR/no-SAR decision before it fires; the same applies to blocking a sanctions hit.
| Rule | What it requires |
|---|---|
| Bank Secrecy Act (BSA) / FinCEN | A Suspicious Activity Report (SAR) must generally be filed within 30 calendar days of initial detection of facts that may constitute a basis for filing (up to 60 days if no suspect is identified), and the SAR and its existence must be kept confidential. |
| OFAC sanctions screening | Parties and transactions are screened against OFAC's SDN and consolidated sanctions lists; a true match must be blocked or rejected and reported to OFAC — a strict-liability obligation. |
| Customer Due Diligence (CDD) / beneficial-ownership rule | Ongoing monitoring and CDD, including identifying beneficial owners of legal-entity customers, underpin whether an alert is escalated. |
A summary for orientation, not legal advice.
A minctrl.process/v1 document: the graph and the hash of the process it becomes.
Import into Minctrl opens this example in your workspace; one click stores it as your first version. Import JSON does the same with the file, and a file changed after download is refused.
Every connector starts in shadow: steps run, nothing leaves Minctrl until you configure a connector and switch it live.
Change signers, time limits and steps on the canvas. Each save is a new version; a running case stays on the version it started with.
The example models the clock: alerts are triaged as they arrive, and each case is tracked against the BSA/FinCEN filing window, where a SAR is generally due within 30 calendar days of detecting the facts that may warrant it. Aging cases are surfaced before they breach, and the timeline is recorded as evidence. Meeting the deadline in production depends on your own monitoring, staffing and filing process. Minctrl holds no certification, and this is not legal advice.
A human. The AI agent screens sanctions and PEP lists, enriches the alert and scores risk, but the SAR/no-SAR decision parks at a gate for a compliance officer to sign. Filing with FinCEN is irreversible, so it is never auto-fired.
Every party and transaction is screened against OFAC's SDN and consolidated lists. Because OFAC compliance is strict-liability, a potential true match is escalated for human adjudication rather than auto-cleared, and the block/reject decision and its rationale are logged with a tamper-evident audit hash.