Agentic Risk Analyst

What could go wrong with this AI use case, and what should we do about it?

Chirag Dani · ARA v3.2.1
LLM: huggingface · meta-llama/Llama-3.3-70B-Instruct · Secure-RAG: connected

Worked example: AI-assisted AML transaction monitoring

ARA-261031-04C8B0 · created 2026-10-31 06:37:15 UTC · source example · model Worked example: prepared in advance, not generated live
complete
Scenario as entered

A Tier-2 bank in Australia proposes to replace its rules-based AML transaction-monitoring engine with an LLM-based agent that reads free-text payment memos, customer notes and adverse-media results to score suspicious-matter reports (SMRs). The agent will draft the SMR narrative and auto-lodge to AUSTRAC once a compliance analyst clicks approve. The model is hosted on a US cloud region.

Next steps for this assessment
EXECUTIVE DECISION
REQUIRES REMEDIATION
Inherent risk Critical → residual risk Medium after the proposed controls
4
Risks
3
Regulatory findings
2
Security threats
4
Controls
3
Remediation actions
0
Evidence passages

Top risks

  • Suspicious matters missed after replacing rules
  • Analysts approve drafts without real review

Conditions for approval

  • Do not retire the rules engine until detection parity is demonstrated
  • Evidence-linked drafts and second-line sampling

Executive narrative

The idea has merit as a prioritisation and drafting aid, but replacing the rules engine without proven parity is not acceptable.

Agent consensus: All analysts flag detection parity as the deciding issue.

Scenario brief

A Tier-2 Australian bank wants an LLM agent to replace rules-based transaction monitoring, score alerts and draft SMRs, lodged after analyst approval; the model is hosted in the US.

Business objective
Improve detection of suspicious matters and reduce analyst effort
ai inferred
Industry
Banking (Tier-2, Australia)
user confirmed
Use case
LLM agent scores alerts and drafts suspicious matter report (SMR) narratives
user confirmed
AI autonomy
human_approval_required
user confirmed
Human oversight
A compliance analyst approves before lodgement
user confirmed
Decision impact
Major: missed or wrong reports have legal consequences
ai inferred

Jurisdictions

AustraliaUnited States (hosting)

Data types

Payment memosCustomer notesAdverse media resultsTransaction data

Affected parties

CustomersAML compliance teamAUSTRAC

Risk domains for the specialists

AML/CTF compliancePrivacy and cross-border dataModel riskAutomation bias

Material information missing

  • How the rules engine is retired or run in parallel
  • Data residency controls in the US region

Alternative approaches

Run alongside the rules engine

Keep the existing rules; use the agent to prioritise and draft.

  • + No loss of detection coverage
  • − Two systems to maintain
Refine the interpretation and re-run (clears the current result)

Refine the interpretation

Your answers are sent to the agents as user-confirmed facts and override the AI's inference. Leave "(no change)" to keep the current value.

Where the AI system will operate. Drives the Compliance agent's regulatory selection.
How independently the AI acts on its output.
What human review sits around the AI.
Which sector's rules apply.

Risk register

Detection gaps and analyst over-reliance are the main risks.

InsignificantMinorModerateMajorSevere
Almost Certain
Likely 1 1
Possible 1 1
Unlikely
Rare
Impact → (rows: likelihood). Cell number = count of risks; hover for IDs.
Inherent ratings follow the Risk agent's rubric: Critical = Almost Certain with Severe or Major impact, or Likely with Severe; High = Likely with Major, or Possible with Severe; Medium = Possible with Moderate or Major, or Likely with Moderate; Low = Rare or Unlikely with Insignificant or Minor impact.
IDCategoryRiskCause → consequenceLikelihoodImpactInherent
R-01ComplianceSuspicious matters missed after replacing rules
The agent fails to flag patterns the rules caught.
Unvalidated replacement → Failure to report; enforcement actionPossibleSevereCritical
R-02OperationalAnalysts approve drafts without real review
Automation bias.
Volume pressure; persuasive drafts → Inaccurate reports lodgedLikelyMajorHigh
R-03PrivacyCustomer data processed offshore
Data sent to a US-hosted model.
Hosting choice → Cross-border disclosure obligations; confidentialityLikelyModerateHigh
R-04ModelHallucinated facts in SMR narratives
Draft contains facts not in the records.
Generative model → Misleading reportsPossibleMajorHigh

Regulatory impact and compliance gaps

AML/CTF reporting duties are central; privacy and prudential obligations also apply. Confirm with legal counsel.

Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (suspicious matter reporting) (Australia) applicable

Why it matters here: The agent supports SMR decisions and drafting.

Impact on this scenario: The program must cover the new monitoring method.

Obligations
  • Report suspicious matters to AUSTRAC within the statutory time frames
  • Do not disclose ('tip off') that a report has been made
  • Maintain an AML/CTF program
Required controls
  • Parallel run before retiring rules
  • Tipping-off controls on outputs

Privacy Act 1988 (APP 8 cross-border disclosure) (Australia) applicable

Why it matters here: Personal information is sent to a US-hosted model.

Impact on this scenario: Contract and assessment of the US provider.

Obligations
  • Take reasonable steps so the overseas recipient handles the information consistently with the APPs
Required controls
  • Data processing agreement
  • Data minimisation

APRA CPS 230 Operational Risk Management (Australia) applicable

Why it matters here: Material reliance on a third-party model provider for a compliance-critical process.

Impact on this scenario: Provider assessment and exit plan.

Obligations
  • Formal agreement with the material service provider
Required controls
  • Service provider due diligence

Compliance gaps

AreaObservationGapRisk createdRemediation
ValidationPlan replaces the rules engine.No evidence the agent detects what the rules detect.CriticalRun both in parallel and compare before any retirement.

Security threats

Free text in memos is an injection path into the agent.

IDThreatAttack vectorAssets at riskL × IInherentMITRE
T-01Prompt injection through payment memos ai_specific
A memo instructs the agent to score the transaction as benign.
Detection and response requirements
  • Detect: Scan inputs for instructions
  • Respond: Escalate flagged items to a person
Customer-controlled free textAlert scores, SMR draftsPossible × Major HighOWASP LLM01:2025
T-02Exposure of SMR content traditional
Confidential report content leaks.
Detection and response requirements
  • Detect: Access logging
  • Respond: Incident response
Logs or provider retentionSMR dataUnlikely × Severe High-

MITRE references are proposed by the model only when it is confident; verify them in ATLAS or ATT&CK.

Controls and residual risk

Parallel running, input sanitisation and evidence-linked drafts bring the residual risk to Medium.

Overall: inherent Critical → residual Medium

IDControlTypeAddressesEffectivenessPriority
C-01Parallel run with the rules engine
Keep the rules engine until detection parity is shown.
PreventiveR-01HighImmediate
C-02Evidence-linked SMR drafts
Every statement in a draft must cite a transaction or record; uncited text is flagged.
PreventiveR-04, R-02MediumImmediate
C-03Quality sampling of approvals
Second-line review of a sample of approved SMRs.
DetectiveR-02MediumNear-term
C-04Data minimisation and onshore option
Send only necessary fields; assess an Australian region.
PreventiveR-03MediumNear-term

Residual risk

RiskInherentControls appliedResidualJustification
R-01 Suspicious matters missed after replacing rulesCriticalC-01MediumParallel running prevents coverage loss.
R-02 Analysts approve drafts without real reviewHighC-02, C-03MediumCitations and sampling expose weak review.
R-03 Customer data processed offshoreHighC-04MediumMinimisation reduces exposure.
R-04 Hallucinated facts in SMR narrativesHighC-02LowUncited statements are flagged.

Residual ratings assume the controls are implemented and work as described. They are projections until the controls are verified.

Remediation plan

0-30 days

IDActionOwnerPriority
A-01Redesign as parallel run alongside the rules engineAML Compliance LeadCritical

30-90 days

IDActionOwnerPriority
A-02Build citation checks into SMR draftsAI EngineeringHigh
A-03Assess cross-border data handling of the US-hosted modelPrivacy OfficerHigh

90+ days

No actions.

Red team: attack the AI

The red team designs 8 adversarial tests for this scenario and judges whether the proposed controls would stop each one.

Agent trace

Pipeline: Scenario Intelligence → Risk, Compliance and Security analysts (in parallel) → Control Analyst → Supervisor. Model: Worked example: prepared in advance, not generated live.

  • 06:37:15example: Worked example loaded (prepared in advance; no model was called).

Downloads

Decision support only, not legal or regulatory advice. AI-generated ratings and citations must be reviewed by a qualified person before they are relied on.