BSA/AML Transaction Monitoring & SAR Filing — impact tolerance ≤ 24 hours — ITOL

Impact tolerance: ≤ 24 hours — monitoring gap > 24h; SAR filing deadline (30 days from detection) must be met (illustrative default — trace the derivation, then replace with your own harm analysis)

Definition: Monitor customer transactions for suspicious activity, produce alerts, investigate, and file SARs (Suspicious Activity Reports) with FinCEN within statutory deadlines.

Why it is designated: BSA/AML (Bank Secrecy Act / anti-money-laundering) monitoring is a legally required control (31 CFR 1020). An extended monitoring gap creates supervisory findings and MRAs (Matters Requiring Attention). If the gap is egregious, enforcement action follows. Note: this is a supervisory-facing service. The UK's PRA (Prudential Regulation Authority) policy would classify it as an 'enabler', but US regulators explicitly treat it as material.