Overlay · not the system of recordHolds sit above scoreAsk Desk is deterministic — no modelLocal
GRC / regulatory analyst
BSA exam in 40 days — SAR evidence thin
FinCEN / BSA exam
Hold · Exam / MRIA · cannot auto-clear
PriorityP2
Severityhigh
PacketReady
Suggested—
This is a hold, not a ticket. A human has to look. Desk will not auto-release it.
Why this is here
Q2 SAR narrative sample failed internal QA on 'complete story' 4 of 12 times.
QA4/12 narratives incomplete
Exam calendarOn-site in 40 days
OpenPagesIssue I-BSA-09 still open from last exam
Recommended. Open a targeted QA loop on narratives. Do not relaunch the whole AML stack.
Failure may be documentation quality, not detection quality. Mixing them will panic the exam team.
Current: Open
Overlay only. Will POST a label to the write-back URL, never a funds release. IBM OpenPages OPSS-Iss:WorkflowStatus=WATCH on reg-bsa-exam. Desk is not the system of record.