OpenChainGraph · AML / AMLR Consolidation · 2 Branches
AML & AMLR Consolidation Chain
Two AML compliance paths, one chain. ART-10 (AMLA transaction typology scorer) anchors both branches with a §4 hash-anchored artifact establishing your financial-crime risk landscape. Branch A covers the core AML programme (customer risk → transaction monitoring → CTR/SAR → policy mandate) for ongoing FATF/6AMLD/BSA obligations. Branch B covers EU AMLR Single Rulebook compliance (obliged entity scope → UBO mapping → CDD framework → readiness scoring) for the July 2027 AMLA full-application deadline.
FATF 40 · 6AMLD · BSA · AMLR 2024/1624ART-10 · OpenChainGraph §4 ArtifactEU AMLR · July 2027 DeadlineClient-side · Zero PIIWave B
⬡ Common entry point — start here
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ART-10 · OpenChainGraph Promoted · chain_depth: 0
AMLA Transaction-Typology Risk Scorer
Score a synthetic transaction graph against AMLA typologies and FATF Travel Rule predicates. Produces an AML risk determination per account/cluster — structuring, layering, smurfing, trade-based ML, round-tripping, and 12 further typology patterns. The typology risk profile establishes your financial-crime exposure before you choose a compliance path. Exports a §4 hash-anchored artifact anchoring the chain.
⬡ OpenChainGraphrisk_control§4 execution_hashchain_depth: 0FATF 40 · EU AMLR 2024/1624
Branch A · AML ProgrammeART-10 → T110 → T116 → T119 → T121 → T131. Total: ~90–120 min.
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T110 · Original Tool
Customer Risk Rating Engine
Establish your customer risk-tier distribution before configuring TM rules. Input your customer population profile to generate Low / Medium / High / EDD segment sizes with regulatory rationale (PEP status, jurisdiction risk, product risk, channel risk, business relationship risk). The risk tier map directly drives TM rule threshold calibration in the next step — high-risk customer clusters warrant tighter monitoring parameters.
Design TM rules calibrated to the risk tier distribution from T110. Configure velocity, threshold, structuring-detection, and cross-border rules per risk segment. Rule parameters are automatically weighted against the high-risk cluster size — a population skewed to High/EDD triggers tighter velocity rules to avoid SAR threshold evasion. Outputs a rule-set configuration for your TM system.
Simulate CTR and SAR filing obligations against your transaction flow. Determines which transactions cross mandatory reporting thresholds (FinCEN $10k CTR / EBA GL structuring), models SAR eligibility under your TM rule outputs, and estimates alert-to-SAR conversion rates. Calibrate your TM rules before live deployment — false-positive rates above 95% are a systemic red flag to regulators.
Draft structurally compliant SAR narratives for transactions flagged by your TM rules (T116) and threshold simulation (T119). Produces the "who, what, when, where, why" narrative required by FinCEN Form 111 and EBA AMLR guidance, in plain language free of legal conclusions. Regulators consistently cite poor SAR narrative quality as a key examination finding — templated drafts anchored to your specific alert facts reduce this risk.
T121Consumes: T119 flagged alertsFinCEN Form 111 · EU AMLR Art. 69
Consolidate the customer risk profile (T110), TM rule configuration (T116), CTR/SAR thresholds (T119), and SAR narrative parameters (T121) into a validated AP2 AML Policy Mandate — a machine-readable JSON with an agent_instructions array ingestible by MCP agent runtimes. The mandate codifies your AML programme's key decision rules in a format that agentic systems can enforce at transaction time.
T131Terminal nodeAP2 AML Policy MandateMCP agent_instructions
A fully configured AML programme — risk tiers, TM rules, CTR/SAR calibration, and machine-readable policy mandate
After Branch A: an ART-10 §4 typology risk profile anchoring the chain, a customer risk-tier distribution with regulatory rationale (T110), a TM rule configuration calibrated to your risk segments (T116), CTR/SAR threshold calibration with alert-to-SAR conversion estimates (T119), SAR narrative templates for flagged alerts (T121), and an AP2 AML Policy Mandate for MCP agent-runtime enforcement (T131). The ART-10 execution_hash anchors your typology assessment — chain the §4 artifact into your BSA/AML programme documentation as a verifiable risk determination.
Branch B · EU AMLR Single RulebookART-10 → T485 → T486 → T487 → T488 → T350. Total: ~90–120 min. Deadline: July 2027.
⚠ Deadline: July 1, 2027
EU AMLR 2024/1624 (the Single Rulebook) applies fully from 1 July 2027. AMLA (the new EU supervisory authority) begins full operations from 2028 but will immediately assume direct supervision of high-risk obliged entities. NCAs are expected to enforce full AMLR compliance from day one of application. Early readiness scoring (T350) is the most effective way to identify gaps while remediation windows remain open.
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T485 · Original Tool
AMLR Obliged Entity Scope Mapper
Classify your entity type against the AMLR Article 3 obliged entity list and determine which AMLR obligations apply in full, in simplified form, or not at all. AMLR significantly expands scope relative to 4AMLD/5AMLD — crypto-asset service providers, crowdfunding platforms, mortgage intermediaries, and new categories of professional service providers are now in scope. Also determines which NCA/AMLA supervisory regime applies.
Map UBO identification obligations under AMLR Article 42–51: the 25% ownership threshold, complex ownership structure analysis, EDD triggers for opaque structures, and UBO register cross-check requirements. AMLR strengthens UBO verification — obliged entities must now independently verify UBO information against registers rather than relying on them as sole source. Identifies where your UBO procedures need to be upgraded.
Classify cash transactions against AMLR Article 80 — the new EU-wide €10,000 cash payment limit applying to traders and professional services. Also maps EDD trigger conditions under AMLR: third countries with strategic deficiencies, PEPs and family members, complex ownership structures, and high-value asset transactions. Produces a cash-limit compliance checklist and EDD policy trigger matrix.
Configure your CDD policy framework for AMLR compliance — SDD (simplified due diligence), standard CDD, and EDD tier definitions with AMLR-specific criteria. AMLR harmonises CDD across the EU for the first time, eliminating the national-transposition variations that created compliance arbitrage under 4AMLD/5AMLD. Produces a structured CDD policy document anchored to AMLR article references.
Score your overall AMLR readiness against the July 2027 deadline. Aggregates the scope mapping (T485), UBO procedure gaps (T486), cash-limit compliance (T487), and CDD framework maturity (T488) into a graded readiness assessment with a prioritised gap list. Identifies which gaps pose the highest NCA/AMLA supervisory risk and should be remediated first. The terminal export of Branch B — a regulatory evidence file for your AMLR readiness programme.
A complete AMLR readiness package — scope determination, UBO gaps, cash-limit compliance, CDD framework, and readiness grade
After Branch B: an ART-10 §4 typology risk profile establishing your financial-crime exposure context, an AMLR obliged entity scope determination and supervisory regime mapping (T485), UBO identification gap analysis against AMLR Article 42–51 (T486), a cash-limit compliance checklist and EDD trigger matrix for AMLR Article 80 (T487), a harmonised CDD policy framework with AMLR article references (T488), and a graded AMLR 2027 readiness score with prioritised remediation roadmap (T350). Use the T350 gap list to drive your AMLR remediation programme before the July 2027 deadline — the ART-10 §4 artifact anchors your typology risk context in the readiness file.
Download the §4 chain definition artifact (hash-anchored composite JSON) or the §13.11 W3C Verifiable Credentials view. Both derive from the chain definition — no new hash is minted. Available after hash computation.