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Governance

Every decision on the record, exactly as it was made

Your SOPs run as written and every case is worked to its deadline. Each action, edit and sign-off is recorded at the time, with what the analyst saw in front of them, and the record cannot be altered afterwards. Built for the moment a regulator asks.

What's on the record

The procedure, the deadline, every action and every decision, recorded as they happened and kept as they were.

Your SOPs, encoded

Each procedure as conditions, steps and escalation paths the agent follows on every case. Change a step and the next case follows it. Every version kept.

SOP library — 24 procedures5
  • High-risk corridor escalation

    AU → SG · v3.2 · Active

    MAS PSN02
  • Sanctions hit handling

    All jurisdictions · v2.1

    Active
  • EDD on PEP transfers

    Tier 1 · v1.4

    Active
  • Threshold breach review

    AUSTRAC · v2.0

    Draft
  • Travel Rule data missing

    Cross-corridor · v1.7

    Active

Written by compliance, not engineering

Thresholds, conditions and actions in plain language, live on the next case. No deployment, no engineering queue. Every change logged with who and why.

Rule: High-risk corridor velocity4 steps
  1. 1

    Corridor matches AU → SG

    Jurisdiction filter

    Running
  2. 2

    Transfer amount > A$5,000

    Threshold check

  3. 3

    Customer transfers > 3 in 7 days

    Velocity pattern

  4. 4

    Counterparty risk score > 70

    Risk gate

Deadlines that escalate

Every step has a clock. The agent warns as it nears, escalates along your path when it passes and logs the hand-off. Nothing ages out in an inbox.

Active SOP deadlines7
StepOwnerSLA
  • Initial triageSarah Chen32m / 1h
  • Counterparty resolutionSarah Chen1h 18m / 2h
  • Counterparty reviewDavid Park3h 22m / 4h
  • Onchain trace + flowDavid ParkAuto · 4m
  • MLRO sign-offJames Liu9h 41m / 12h
  • AUSTRAC SMR draftJames LiuAwaiting sign
  • AUSTRAC submissionJames LiuOverdue

Decisions with their context

What was decided, by whom and what they saw at the time: the case file, the counterparty profile, the rules in force and the SOP version.

Decision

Approved · STR not required

CSE-2847
David Park· MLRO·14:47 AEST · 12 Apr 2026

Context captured

  • Brief snapshot:v3 · 11.4s gen
  • Counterparty:VASP Track 94/100
  • Jurisdiction:MAS PSN02
  • SOP version:Cross-border EDD v3.2
  • Reasoning:free-text recorded
Sealed · immutable record

When the regulator asks

A request for evidence should take a search, not a fortnight of reconstruction.

The request lands

A regulator asks for the compliance process behind a transfer from 11 months ago. Your MLRO searches by the transfer and the complete trail comes back.

Investigation log4 events
  1. Transfer ID entered

  2. Full trail retrieved

  3. Context snapshots loaded

  4. Export prepared

4 resolvedChain intact

What was known at each step

The trail shows what your analyst had in front of them at every decision point: the case file they read, the counterparty profile as it was, the rules in effect and the SOP version that applied.

Investigation log5 events
  1. Investigation brief read

    Six source attachments accessed · Chainalysis, Sumsub, World-Check, transfer history, jurisdiction DB, sanctions list.

    Audit ledger

  2. Counterparty profile snapshot taken

    VASP Track entry for SatoshiX (SG) frozen at this hash · cryptographically attested.

    Audit ledger

  3. Jurisdiction rules applied

    MAS PSN02 v3.2 — SGD 1,500 threshold, 23 required fields.

    Jurisdiction DB

  4. SOP version recorded

    Cross-border EDD SOP v3.2 active at decision time.

    Policy registry

  5. MLRO disposition signed

    j.martinez signed with cryptographic key — chain integrity verified.

    Audit ledger

4 resolvedChain intact

Evidence handed over

Export the filtered trail as a PDF or structured data. Every record carries its timestamp, actor, action and context, and none of it has been altered since it was written.

Recommended action4 channels

Trail complete — all decision points documented

Ready

Transfer

TRF-5021

Events

14 trail records

Period

May 2025

Export

Trail exported by [email protected] — 12 Apr 2026 14:32 AEST

A record that can't be rewritten

Records are written once. A correction is a new entry alongside the original, never a change to it. If a risk factor is re-read, both readings stay. If a counterparty's profile changes next month, what your analyst saw this month stays on file. When a regulator asks which procedure was in effect on a given date, the answer is already there.

Cryptographic integrityIndependently audited
  • Storage model

    Append-only, write-once· Infrastructure architecture

  • Integrity method

    tamper-evident record· Security documentation

  • Last verification

    12 Apr 2026 — chain intact· Automated integrity check

  • Certification

    Independently audited — current· Annual audit report

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