Reviewing and clearing historical AML hits

Reviewing and clearing historical AML hits

Accupe no longer runs sanctions or PEP screening, so no new hits are being created. What this article covers is the queue of hits your firm generated while the feature was live and never closed out. Those screenings are regulated records: they were not deleted, and they still need a decision recorded against them so your audit trail isn't left with open items.

Any such screening at Potential Match or Confirmed Match sits in status Pending Review until someone actually looks at it and records a decision. Accupe calls this a disposition, and it's built around a four-eyes rule: the one decision that downgrades risk always needs two different people to sign off. Both the review queue and the four-eyes workflow are still fully functional, so an outstanding queue can be worked to zero.

Where to review

Open Compliance Radar (Cmd+K or the sidebar, visible to admin and manager roles) and look at the "Pending AML hits" panel. It lists every screening at status Pending Review across your whole client base, with columns for the name screened, the client, number of hits, risk level, and a Review button. Click Review to open the Review AML hit modal for that screening.

You can also jump straight to a specific screening by opening a link in the form of your Compliance Radar URL with a focus parameter set to the screening's ID, useful if you're sharing a specific hit with your MLRO by email or chat, since it opens the review modal automatically once the page loads.

Making a decision

1. Open the Review AML hit modal for the pending screening.
2. Choose one of three outcomes: Cleared - false positive, Escalate for further review, or Confirmed true match.
3. Write a reason of at least 30 characters. A short note like "checked, fine" won't be accepted; explain what you actually checked (date of birth, nationality, employer, or whatever ruled the match in or out) and why you reached that conclusion.
4. Submit.

Why false-positive clearances need two people

Clearing a hit is the only decision that lowers a client's risk position, so it's the only one that requires a second reviewer. Once the first admin or manager submits "Cleared - false positive," Accupe records them as the first reviewer but leaves the screening in Pending Review. A second, different admin or manager then has to open the same screening and confirm the clearance before status actually flips to Cleared. If the same person tries to be both reviewers, Accupe blocks the second submission with "A second reviewer is required to confirm this disposition. Please ask a different admin or manager to sign off.", a rule enforced both by the API and by a database-level check, so it can't be worked around by resubmitting.

Who can review

You need the equivalent of the approve_kyc permission, which admins and managers have by default and staff do not. A staff member attempting to disposition a hit will see "Only admins or managers can disposition AML hits."

Tip: Compliance Radar's Review AML hit modal is now the only place a disposition can be recorded. The old per-client AML tab, and the quick status dropdown on its Screening History table, were removed along with the screening feature. That's the better route anyway: it's the one that captures the written reason and, where it applies, the second reviewer your audit trail will need.