Financial Crime · Agent pack
New packSAR narrative quality
Cadre pack · Redliner
Drafts and checks a narrative while treating unsupported facts as a failed evaluation.
Demonstrated on representative cases. Source coverage, thresholds, policy interpretation, escalation design, and performance require institution-specific validation.
Operating dossier
The job, permitted decisions, and owner
Mandate
Drafts the FinCEN SAR narrative from an investigation packet, then checks each revision against a completeness rubric; any fact absent from the packet fails the evaluation.
- Case arrives with
- Packet ID · Packet · Customer name · Packet · Period · Packet · Subjects
- Allowed outcomes
- Structured outcome for review
- Where it fits
- Alert to SAR
Operating logic
- 01Drafts the narrative section of a SAR from an investigation packet, then checks revisions against a configured completeness rubric within a defined review limit.
- 02Grounding is a non-negotiable evaluation rule: any amount or name the packet does not establish fails the case rather than being introduced into a regulatory draft.
- 03Gaps the packet cannot close are recorded as unresolved items and written around honestly, not papered over.
- 04States observations, not conclusions of law — the pattern of deposits under a reporting threshold, not an accusation of laundering.
- 05Stops at the rubric bar or the configured review limit, whichever comes first; the narrative is not padded to chase a score.
Decision logic
- 01Drafts the narrative section of a SAR from an investigation packet, then checks revisions against a configured completeness rubric within a defined review limit.
- 02Grounding is a non-negotiable evaluation rule: any amount or name the packet does not establish fails the case rather than being introduced into a regulatory draft.
- 03Gaps the packet cannot close are recorded as unresolved items and written around honestly, not papered over.
- 04States observations, not conclusions of law — the pattern of deposits under a reporting threshold, not an accusation of laundering.
- 05Stops at the rubric bar or the configured review limit, whichever comes first; the narrative is not padded to chase a score.
- Must not
- Invent missing evidence or act outside the permitted outcomes.
- Human owner
- Unresolved source gaps and filing approval
- Evidence retained
- Structured outcome, observed path, and the source evidence used.
Case and record
One case, from supplied evidence to recorded decision
Supplied case
- Packet ID
- PKT-RICH-001
- Packet · Customer name
- Halcyon Imports LLC
- Packet · Period
- 03 Jan 2026 - 21 Jan 2026
- Packet · Subjects
- 3 items
- Packet · Red flags
- Twelve cash deposits each between 8,200 and 9,600 USD, all below the 10,000 USD CTR reporting threshold, Deposits clustered across three branches over nineteen days, Deposit volume inconsistent with the stated import-wholesale profile and prior account history, Funds aggregated then wired out within 48 hours of deposit to a single overseas beneficiary
- Packet · Transactions
- 5 items
- Packet · Typology assessment
- Cash structuring (smurfing) to evade the 10,000 USD CTR threshold, followed by rapid layering via outbound international wire. Consistent with placement-then-layering money laundering.
- Packet · Recommendation
- SAR
- Packet · Recommendation rationale
- Pattern of sub-threshold cash deposits aggregated and wired offshore is a textbook structuring-and-layering typology with no legitimate business explanation in the file.
View the case data
Case key rich-structuring-complete
{
"packetId": "PKT-RICH-001",
"packet": {
"customerName": "Halcyon Imports LLC",
"period": "03 Jan 2026 - 21 Jan 2026",
"subjects": [
{
"name": "Halcyon Imports LLC",
"role": "account holder",
"sanctionsResult": "clear",
"adverseMedia": "none"
},
{
"name": "Daniel Okoro",
"role": "beneficial owner",
"sanctionsResult": "clear"
},
{
"name": "Riverside Cash & Carry",
"role": "counterparty (originator)"
}
],
"redFlags": [
"Twelve cash deposits each between 8,200 and 9,600 USD, all below the 10,000 USD CTR reporting threshold",
"Deposits clustered across three branches over nineteen days",
"Deposit volume inconsistent with the stated import-wholesale profile and prior account history",
"Funds aggregated then wired out within 48 hours of deposit to a single overseas beneficiary"
],
"transactions": [
{
"id": "TX-9001",
"date": "03 Jan 2026",
"amount": 9400,
"currency": "USD",
"direction": "inbound",
"method": "cash deposit",
"counterparty": "Branch 014"
},
{
"id": "TX-9002",
"date": "06 Jan 2026",
"amount": 8800,
"currency": "USD",
"direction": "inbound",
"method": "cash deposit",
"counterparty": "Branch 022"
},
{
"id": "TX-9003",
"date": "09 Jan 2026",
"amount": 9600,
"currency": "USD",
"direction": "inbound",
"method": "cash deposit",
"counterparty": "Branch 014"
},
{
"id": "TX-9004",
"date": "14 Jan 2026",
"amount": 8200,
"currency": "USD",
"direction": "inbound",
"method": "cash deposit",
"counterparty": "Branch 031"
},
{
"id": "TX-9010",
"date": "21 Jan 2026",
"amount": 71200,
"currency": "USD",
"direction": "outbound",
"method": "international wire",
"counterparty": "Aurora Trading FZE",
"counterpartyCountry": "United Arab Emirates",
"flag": "aggregated structured cash wired out within 48 hours"
}
],
"typologyAssessment": "Cash structuring (smurfing) to evade the 10,000 USD CTR threshold, followed by rapid layering via outbound international wire. Consistent with placement-then-layering money laundering.",
"recommendation": "SAR",
"recommendationRationale": "Pattern of sub-threshold cash deposits aggregated and wired offshore is a textbook structuring-and-layering typology with no legitimate business explanation in the file."
}
}Evaluation and limits
Evaluation coverage and stopping points
Published evaluation map
Expected decisions, boundaries, and costly failure modes.
These cases show what the pack is asked to decide, when it should stop, and which plausible errors the evaluation is meant to expose. They are not a reliability score or independent validation.
Expected and borderline behavior
Routine judgments, close calls, and named stopping points.
Full packet
structuring plus layering. The draft should cover the who, what, when, where, why, and how from the supplied record, then be checked against the configured completeness rubric.
Case key
rich-structuring-completeMedium packet
a BEC redirection. The narrative should cover the five Ws and the how from the facts actually present, no further.
Case key
medium-bec-most-facts
Boundary and misuse cases
Plausible inputs that could produce a costly or overconfident decision.
Sparse packet
dates, counterparties, and a clear typology are missing. The pack must not invent them — any amount or name absent from the packet fails the case, and the gaps remain unresolved.
Case key
adv-sparse-no-fabrication
Operating fit
Workflow placement and validation
Operating pattern
Draft, check, revise
Separate drafting from checking and stop when the work meets clear requirements—or when the agreed review limit is reached.
Decision sequence and workflow placement
- 01Draft from evidence
- 02Check named requirements
- 03Return specific gaps
- 04Revise
- 05Complete or refer
Wider workflows
Institution-specific validation
These questions remain open until the pack is fitted to an institution.
Validation questions
- Policy and legal interpretation
- Source coverage, quality, and freshness
- Thresholds and exception calibration
- Integration and degraded-mode behavior
- Human approval and escalation design
- Performance on the institution’s own case mix
Inputs, actions, and outcomes
- Packet ID
- Packet · Customer name
- Packet · Period
- Packet · Subjects
- Packet · Red flags
- Packet · Transactions
- Packet · Typology assessment
- Packet · Recommendation
- Packet · Recommendation rationale
- Draft narrativedraft_narrative
- Critiquecritique
- Commit narrativecommitcommit_narrative
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