Level 1 Review: The potential alert is reviewed to determine whether it is a true match, false positive, or needs more information to resolve.
Level 2 and 3 Review: Escalation: If there’s a potential true match, the case is escalated for further analysis according to your internal compliance procedures.
- Customer Request for Information (RFI) : If the alert results in the transaction being placed on hold or declined, the customer can be notified. This is a risk based decision, and is governed by the laws of the jurisdictions through which the transaction passes through. Some laws make it illegal to “tip-off” a bad actor. For example, if you believe that the alert shows terrorist financing, you should not inform the terrorist financier that you know that they are financing terrorism. However, if you believe that the transaction is wrongly on hold and you can release it with more information, you can send an RFI.
- If you need assistance in crafting policies and procedures please email sales@castellum.ai
Decision:
- If the alert is confirmed as a true positive, the transaction may be returned to the original sender, or it may be required to be frozen (sometimes referred to as blocked) and you may need to file a report of blocked property with relevant regulators. This depends on your local regulator, the company’s policies and details around the true positive. You may also need to notify law enforcement or regulatory agencies about the alert.
- If the issue is cleared: The transaction may be released and processed as usual, and the customer will be informed that the hold has been lifted.
- If you need assistance in crafting policies and procedures please email sales@castellum.ai