AML Lookback Closure Cycle

Three-step BSA/AML lookback closure cycle over the re-screened population, the resulting disposition sampling frame, and the caller's own per-sampled-item disposition records. Step 1 reconciles re-screening completeness against the declared population, excluding any period with no preserved list snapshot as unverifiable rather than screening it against today's list. Step 2 builds a deterministic disposition sampling frame and reviewer workload allocation over the verifiable population. Step 3 rolls up disposition-coverage, disposition-rationale-presence, and a population-to-sample tie-out into a closed gate value. A hold or escalate outcome routes the cycle to the BSA Officer as reviewer; a completed lookback, including an auto_pass rollup, still requires a separate approval record naming the BSA Officer or designated compliance role as approver. Customer id, alert id, and transaction reference are salted throughout; no plaintext identifier ever enters the chain. This bundle is the institution's own evidence of its lookback closure basis, not a supervisory determination.

OpenChainGraph · 3 Steps compliance control Hash-Anchored §4 chain_depth:3 Client-Side · Zero PII

Chain Stages · 3 Steps

1 ROOT node

Lookback Completeness Reconciler art-470-lookback-completeness-reconciler

verifiable_source_count, verifiable_extract_count, and unverifiable_periods (excluded from re-screen scope) feed the disposition sampling frame's population definition; population size also feeds the rollup's population-to-sample tie-out

MCP Call · reconcile_lookback_completeness

{
  "jsonrpc": "2.0",
  "method": "tools/call",
  "params": {
    "name": "reconcile_lookback_completeness",
    "arguments": {}
  },
  "id": 1
}

↓

2 D2 node

Disposition Sampling Frame art-471-disposition-sampling-frame

reviewer_workload allocation and the sample frame's declared population size feed the disposition rollup kernel, alongside the caller's per-sampled-item disposition records

MCP Call · build_disposition_sampling_frame

{
  "jsonrpc": "2.0",
  "method": "tools/call",
  "params": {
    "name": "build_disposition_sampling_frame",
    "arguments": {}
  },
  "id": 1
}

↓

3 TERMINAL node hold / escalate → BSA Officer

AML Lookback Disposition Rollup art-534-aml-lookback-disposition-rollup

Disposition-coverage, disposition-rationale-presence, and population-to-sample tie-out roll up into a closed §27.4 gate_policy value that closes the lookback's evidence bundle. Final stage.

§27 Human Accountability gate: a hold or escalate rollup routes the cycle to the BSA Officer as reviewer before it is treated as settled. A completed lookback, including an auto_pass rollup, still requires a separate approval record naming the BSA Officer or designated compliance role as approver (§27.1); automation never substitutes for that named sign-off.

MCP Call · roll_up_aml_lookback_disposition

{
  "jsonrpc": "2.0",
  "method": "tools/call",
  "params": {
    "name": "roll_up_aml_lookback_disposition",
    "arguments": {}
  },
  "id": 1
}