Automated Monitoring vs Human Judgment
Mandate human investigator sign-off on every SAR filing so automated detection augments rather than replaces the qualified MLRO judgment required by FATF.
CyberTRIZ analysis · Regulatory contradiction R138 · one of 8,235 worked contradictions published by CyberTRIZ.AI
Regulations
Contradiction
Resolution
Use automated monitoring for detection while reserving final reporting decisions for qualified AML investigators.
Evidence
Monitoring Rules
Investigation Files
SAR Procedures
Kpis
Alerts investigated
SAR accuracy rate
Controls that address this (13)
FATF-AML-001 - Implement Risk-Based AML/CFT Approachoperational · critical priority · Implement a risk-based approach to AML/CFT covering: national risk assessment awareness, institutional risk assessment, risk-based allocatioFATF-CDD-001 - Implement FATF-Standard Customer Due Diligenceoperational · critical priority · Apply CDD measures to all customers: identify and verify customer identity, identify beneficial owners, understand the purpose of the busineFATF-R1-001 - Institutional AML/CFT Risk Assessmentgovernance · critical priority · Conduct a comprehensive institutional AML/CFT risk assessment covering: products and services, customer types, delivery channels, and geogra