Rule-to-Action Map

This page translates source rules into practical AML agent actions. It is the bridge between regulatory-style standards and the actual checklist an analyst follows.

1. Risk-Based Approach #

Source basis: SRC-FATF-001 / Recommendation 1.

Plain-language rule: not every customer needs the same level of review. Higher risk means deeper checks; lower risk may allow simpler checks if no suspicion exists.

Agent action:

1. Identify risk factors.
2. Assign preliminary risk.
3. Decide SDD / CDD / EDD according to policy.
4. Document why the level of review is proportionate.

2. Customer Due Diligence #

Source basis: SRC-FATF-001 / Recommendation 10.

Plain-language rule: know who the customer is, who owns or controls them, why they need the relationship and whether their activity makes sense over time.

Agent action:

1. Identify the customer.
2. Verify identity using reliable information.
3. Identify beneficial owner or controlling person.
4. Understand purpose and intended nature.
5. Set ongoing monitoring expectations.
6. Stop or escalate if required information cannot be obtained.

3. Record Keeping #

Source basis: SRC-FATF-001 / Recommendation 11.

Plain-language rule: AML decisions must be reconstructable later.

Agent action:

1. Save identity evidence.
2. Save screening results.
3. Save case notes.
4. Save documents and source links.
5. Save rationale for risk rating and decision.

4. PEP Review #

Source basis: SRC-FATF-001 / Recommendation 12.

Plain-language rule: politically exposed persons can create higher corruption, bribery or abuse-of-office risk. The risk often extends to family members and close associates.

Agent action:

1. Screen the customer, UBOs and controllers for PEP exposure.
2. Classify the role, country/geography, date and closeness of exposure.
3. Request source of wealth and source of funds evidence where required.
4. Escalate high-risk PEP cases for senior/compliance approval.
5. Apply enhanced ongoing monitoring where needed.

5. Sanctions / Targeted Financial Sanctions #

Source basis: SRC-FATF-001 / Recommendations 6 and 7; SRC-UN-001.

Plain-language rule: listed persons and entities must not be provided with funds or economic resources where applicable. Possible matches must be reviewed carefully and true matches must be escalated immediately.

Agent action:

1. Screen all relevant parties and connected objects.
2. Compare identifiers: name, date of birth, address, nationality, registration number, ownership/control, aliases.
3. Clear false positives with evidence.
4. Escalate possible unresolved matches.
5. Escalate true matches immediately and follow the adopter configuration.

6. Higher-Risk Countries / Geographic Exposure #

Source basis: SRC-FATF-001 / Recommendation 19; SRC-FATF-002.

Plain-language rule: geography is a risk factor, not an automatic decision. Exposure to higher-risk jurisdictions may require EDD or additional controls.

Agent action:

1. Identify geographic connections: residence, incorporation, operations, counterparties, banks, shipment routes, wallets, IP or payment flow.
2. Check whether FATF or other configured sources flag the geography.
3. Decide whether EDD is required.
4. Document how the geographic risk affects the overall risk rating.

7. Suspicious Activity / STR-SAR Logic #

Source basis: SRC-FATF-001 / Recommendations 20 and 21; SRC-EGMONT-001.

Plain-language rule: when there is suspicion or reasonable grounds to suspect ML/TF, the case should be escalated to the proper reporting function. The customer must not be tipped off.

Agent action:

1. Identify suspicion indicators.
2. Avoid customer communication that could reveal suspicion.
3. Prepare internal escalation memo.
4. Send to MLRO/compliance owner.
5. Preserve evidence and confidentiality.

8. Internal Controls #

Source basis: SRC-FATF-001 / Recommendation 18; SRC-BASEL-001.

Plain-language rule: AML is not just individual checks. A firm needs policies, controls, training, compliance management and independent testing.

Agent action:

1. Follow approved procedures.
2. Record deviations and exceptions.
3. Use standard templates.
4. Escalate control gaps.
5. Support auditability through clean evidence packs.

9. Crypto / VASP AML #

Source basis: SRC-FATF-001 / Recommendation 15; SRC-FATF-003.

Plain-language rule: virtual asset activity can carry ML/TF/PF risk and requires risk assessment, screening, wallet/entity review and transaction context.

Agent action:

1. Identify wallet, VASP, blockchain and transaction context.
2. Screen parties and wallet exposure where tools are available.
3. Look for mixers, darknet, scams, ransomware, sanctioned exposure or high-risk services.
4. Assess source and destination of funds.
5. Escalate unresolved or serious exposure.

10. Trade-Based Money Laundering #

Source basis: SRC-FATF-006.

Plain-language rule: trade can be abused to move value using false pricing, fake documents, unusual routing or mismatched goods and payments.

Agent action:

1. Review buyer, seller, goods, route, value and documents.
2. Look for invoice mismatch, over/under pricing, unusual shipping route, vague goods, dual-use goods or inconsistent counterparties.
3. Request supporting documents.
4. Escalate suspicious or unexplained trade patterns.

11. Tom Custos practical control: Digital Jurisdiction Exposure #

Boundary: this is not a separate FATF-mandated check. It is a practical control that helps analysts document digital infrastructure inconsistencies under a broader risk-based approach.