A large regional bank required a qualified, independent third party to perform risk-based procedures designed to provide reasonable assurance that its FCRM anti-money laundering system’s transaction monitoring, customer risk rating, and watch list filtering applications were functioning as designed and intended.

The Solution

RiskSpan reviewed existing materials, past audits and results, testing protocols and all documentation related to the bank’s model risk management standards, model setup and execution. We inventoried all model data sources, scoring processes and outputs related to the AML system.

The solution consisted of testing each of the five model segments: Design and Development; Input Processing; Implementation; Output and Use; and Performance.

The solution also quantified risk and exposure of identified gaps and limitations and presented sound industry practices and resolutions. 


  • A sustainable and robust transaction monitoring tuning methodology, which documented the bank’s approach, processes to be executed, frequency of execution, and the governance structure for executing tuning and optimization in the AML model. This included collecting and assessing previous regulatory feedback.
  • A framework that included a formal, documented, consistent process for sampling and analysis procedures to evaluate the ALM system’s scenarios and change control documentation.
  • A process for managing model risk consistent with the bank’s examiner expectations and business needs.