The Challenge
By late 2023, the Bank's Financial Crimes Unit was reaching a breaking point. As the institution grew through strategic acquisitions, its legacy rules-based transaction monitoring system was generating an unmanageable volume of alerts with a false positive rate exceeding 90%.
Analysts were spending thousands of hours annually on "Level 1" triage—manually reviewing legitimate transactions flagged simply because they exceeded rigid dollar thresholds or matched broad geographic parameters.
The Cloud Block: The Bank's Chief Data Officer identified Generative AI as a potential solution, but the initiative hit a hard wall:
- Data Egress & Sovereignty: The CISO refused to approve any solution that required sending PII or sensitive financial data to a third-party public cloud
- Regulatory Defensibility (SR 11-7): The Model Risk Management team warned that commercial "black box" LLMs failed to meet Federal Reserve SR 11-7 standards for "conceptual soundness"—if the Bank could not explain exactly how the AI reached a decision, the model would not pass an OCC examination