How a Reviewer Might Test Your Consistency by TechnoXander

AML Consistency Testing in the UK and Europe: A Mock Sample

Imagine a reviewer pulls two closed cases. Same customer type, same pattern, two different outcomes. They ask one question: why? How well your records answer it says a great deal about your organisational memory.

In short: different outcomes are fine when the facts differ. What a reviewer cannot accept is "we don't know why".

Run the mock sample

  1. Pick two closed cases with similar profiles and different outcomes.
  2. For each, write one line: what was the question, and what evidence settled it?
  3. Mark whether either analyst could see the other case.
  4. Check dates: did circumstances change between the two?
  5. Note anything you could not answer from the record alone.

What the results tell you

If the difference is explained by facts, your decisions are consistent. If it is explained by "different analyst", you have a memory problem, and it will not show in a closure dashboard. The gap between having a process and having quality is the subject of process versus quality in AML programmes.

Slides that walk through the reuse question are here: Old Decision, New Case.

If you are using AI to help

Whatever retrieves earlier cases should show the date, scope and status of each one so analysts can judge relevance. See what the FCA expects of AML AI models. A diagram of what a good record contains: Anatomy of a decision record.

Conclusion

A good sample test costs an afternoon and shows where reasoning goes missing. TechnoXander builds investigation tooling so earlier reasoning is available when a case opens.

General information, not legal advice. Hypothetical exercise for illustration.

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