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DoneSTR filed
DoneSupervisory expectation has moved. The question is no longer whether an institution has a transaction monitoring system, but whether it can demonstrate that the system is effective. That demonstration needs evidence most banks cannot produce on demand: why a threshold sits where it sits, what the last rule change did to risk coverage, how a particular alert became a filing, and how long each step of that journey took.
“The question is no longer whether you have a system. It is whether you can show it works, and most banks discover the answer during an inspection rather than before one.”