diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004221.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004221.txt new file mode 100644 index 0000000000000000000000000000000000000000..b400e206412989b30c3b7a4fc19c718f50a81154 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004221.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004221 +Opened: 2024-08-09 Investigator: INV-007 Severity: high +Customer: CUST-01279 — distribution operating in WA. + +1. BACKGROUND +The customer is a distribution licensed in WA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004222.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004222.txt new file mode 100644 index 0000000000000000000000000000000000000000..3969ecc4004a2c03d25be2e20e91a700f42e3dab --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004222.txt @@ -0,0 +1 @@ +Case CASE-004222 opened 2019-03-25 re: customer CUST-01280 (testing_lab, WA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-002. Suspicious activity identified consistent with cash_threshold. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004223.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004223.txt new file mode 100644 index 0000000000000000000000000000000000000000..fe95ee743871e36e77d442c40e70da063ae6c3eb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004223.txt @@ -0,0 +1 @@ +Case CASE-004223 opened 2019-12-04 re: customer CUST-01280 (testing_lab, WA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004224.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004224.txt new file mode 100644 index 0000000000000000000000000000000000000000..67b7b52a5d50cccfd8617a3cdb690960d592039c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004224.txt @@ -0,0 +1 @@ +Case CASE-004224 opened 2020-01-06 re: customer CUST-01280 (testing_lab, WA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004225.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004225.txt new file mode 100644 index 0000000000000000000000000000000000000000..551b2c8227931bb3048b727e2729088e57f5f413 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004225.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004225 +Opened: 2022-03-21 Investigator: INV-006 Severity: high +Customer: CUST-01280 — testing_lab operating in WA. + +1. BACKGROUND +The customer is a testing_lab licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004226.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004226.txt new file mode 100644 index 0000000000000000000000000000000000000000..e4849366acbb7627cf9e84692fbf7830704ae2a8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004226.txt @@ -0,0 +1 @@ +Case CASE-004226 opened 2020-02-05 re: customer CUST-01281 (dispensary, WA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-006. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004227.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004227.txt new file mode 100644 index 0000000000000000000000000000000000000000..bfb66aa91b641e77c7bffd8053b39217b86f26ab --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004227.txt @@ -0,0 +1 @@ +Case CASE-004227 opened 2020-10-05 re: customer CUST-01281 (dispensary, WA). Alert type: high_risk_jurisdiction. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004228.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004228.txt new file mode 100644 index 0000000000000000000000000000000000000000..eb03c1754f7be538f7ae4f86f0a73cfb9fcf01a1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004228.txt @@ -0,0 +1 @@ +Case CASE-004228 opened 2020-12-03 re: customer CUST-01281 (dispensary, WA). Alert type: high_risk_jurisdiction. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004229.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004229.txt new file mode 100644 index 0000000000000000000000000000000000000000..04891b9f333b01b28f6a5e3270544263afc65cda --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004229.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004229 +Opened: 2021-08-04 Investigator: INV-002 Severity: critical +Customer: CUST-01281 — dispensary operating in WA. + +1. BACKGROUND +The customer is a dispensary licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004230.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004230.txt new file mode 100644 index 0000000000000000000000000000000000000000..231c46460c41bd13f715a6275032d285ff6a5125 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004230.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004230 +Opened: 2021-12-02 Investigator: INV-008 Severity: high +Customer: CUST-01281 — dispensary operating in WA. + +1. BACKGROUND +The customer is a dispensary licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004231.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004231.txt new file mode 100644 index 0000000000000000000000000000000000000000..3c10d42348af2d5cea8993123b9063c2bd99f147 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004231.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004231 +Opened: 2022-10-04 Investigator: INV-008 Severity: high +Customer: CUST-01282 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004232.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004232.txt new file mode 100644 index 0000000000000000000000000000000000000000..65d3e24d0a5bea10c4e2eeccf2fb8bcaac867e22 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004232.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004232 +Opened: 2023-02-06 Investigator: INV-004 Severity: high +Customer: CUST-01282 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004233.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004233.txt new file mode 100644 index 0000000000000000000000000000000000000000..24024fe36e3fc115838cac9f11ac4dd28448924b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004233.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004233 +Opened: 2023-04-11 Investigator: INV-009 Severity: critical +Customer: CUST-01282 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004234.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004234.txt new file mode 100644 index 0000000000000000000000000000000000000000..9353d4d8befcfe362c63089537fc6588181d36f1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004234.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004234 +Opened: 2022-12-30 Investigator: INV-007 Severity: high +Customer: CUST-01283 — manufacturing operating in NV. + +1. BACKGROUND +The customer is a manufacturing licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004235.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004235.txt new file mode 100644 index 0000000000000000000000000000000000000000..6243be98c6fd11102015a81d44070444a04e8028 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004235.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004235 +Opened: 2023-11-07 Investigator: INV-001 Severity: high +Customer: CUST-01283 — manufacturing operating in NV. + +1. BACKGROUND +The customer is a manufacturing licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004236.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004236.txt new file mode 100644 index 0000000000000000000000000000000000000000..9883345bcd317abde4796f34a713f13c9c060c01 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004236.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004236 +Opened: 2024-03-18 Investigator: INV-003 Severity: high +Customer: CUST-01283 — manufacturing operating in NV. + +1. BACKGROUND +The customer is a manufacturing licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004237.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004237.txt new file mode 100644 index 0000000000000000000000000000000000000000..a63e3844aab1ff7a007b8f50a49db37cf5d34728 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004237.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004237 +Opened: 2024-04-02 Investigator: INV-007 Severity: high +Customer: CUST-01283 — manufacturing operating in NV. + +1. BACKGROUND +The customer is a manufacturing licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type negative_news generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004238.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004238.txt new file mode 100644 index 0000000000000000000000000000000000000000..7ea614061a46442178176fe3f5cb81fddd8dd05b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004238.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004238 +Opened: 2024-06-07 Investigator: INV-010 Severity: high +Customer: CUST-01283 — manufacturing operating in NV. + +1. BACKGROUND +The customer is a manufacturing licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004239.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004239.txt new file mode 100644 index 0000000000000000000000000000000000000000..ec710b892ae0d8bc294fea93403e63e3dfd22b9e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004239.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004239 +Opened: 2024-07-05 Investigator: INV-003 Severity: high +Customer: CUST-01283 — manufacturing operating in NV. + +1. BACKGROUND +The customer is a manufacturing licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004240.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004240.txt new file mode 100644 index 0000000000000000000000000000000000000000..31451d94fae48975bafe51cc0517cae07667e9ad --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004240.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004240 +Opened: 2024-10-07 Investigator: INV-010 Severity: high +Customer: CUST-01283 — manufacturing operating in NV. + +1. BACKGROUND +The customer is a manufacturing licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004241.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004241.txt new file mode 100644 index 0000000000000000000000000000000000000000..2f8ebd631466581d880ad8a4261a804a9951a5c0 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004241.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004241 +Opened: 2022-10-27 Investigator: INV-006 Severity: moderate +Customer: CUST-01284 — testing_lab operating in CO. + +1. BACKGROUND +The customer is a testing_lab licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004242.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004242.txt new file mode 100644 index 0000000000000000000000000000000000000000..e17a54d2d26dd8363b19983dbb4c87dfb1d49947 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004242.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004242 +Opened: 2023-01-16 Investigator: INV-009 Severity: critical +Customer: CUST-01284 — testing_lab operating in CO. + +1. BACKGROUND +The customer is a testing_lab licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004243.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004243.txt new file mode 100644 index 0000000000000000000000000000000000000000..b75b0049c3bdc94058ac7d7ed61dd47d4a2508b2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004243.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004243 +Opened: 2023-03-03 Investigator: INV-008 Severity: high +Customer: CUST-01284 — testing_lab operating in CO. + +1. BACKGROUND +The customer is a testing_lab licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004244.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004244.txt new file mode 100644 index 0000000000000000000000000000000000000000..0134705c99c8ccfc04be5b227c893b72c97ed16c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004244.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004244 +Opened: 2023-06-16 Investigator: INV-005 Severity: high +Customer: CUST-01284 — testing_lab operating in CO. + +1. BACKGROUND +The customer is a testing_lab licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004245.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004245.txt new file mode 100644 index 0000000000000000000000000000000000000000..0e059b52fe6f4de3709770bb535cda2f20d72ea5 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004245.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004245 +Opened: 2023-10-25 Investigator: INV-001 Severity: high +Customer: CUST-01285 — event_organizer operating in WA. + +1. BACKGROUND +The customer is a event_organizer licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004246.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004246.txt new file mode 100644 index 0000000000000000000000000000000000000000..5d1d5cd5503ad0ef7cb7158e3b7a8276035538b2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004246.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004246 +Opened: 2023-11-17 Investigator: INV-006 Severity: high +Customer: CUST-01285 — event_organizer operating in WA. + +1. BACKGROUND +The customer is a event_organizer licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004247.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004247.txt new file mode 100644 index 0000000000000000000000000000000000000000..6298a5f59718a8c351fb2b32f0373f9975f89e56 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004247.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004247 +Opened: 2024-03-11 Investigator: INV-003 Severity: critical +Customer: CUST-01285 — event_organizer operating in WA. + +1. BACKGROUND +The customer is a event_organizer licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004248.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004248.txt new file mode 100644 index 0000000000000000000000000000000000000000..e0ee5384b5f34b081b2fa62564d6738cb296f549 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004248.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004248 +Opened: 2024-11-18 Investigator: INV-001 Severity: high +Customer: CUST-01285 — event_organizer operating in WA. + +1. BACKGROUND +The customer is a event_organizer licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004249.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004249.txt new file mode 100644 index 0000000000000000000000000000000000000000..6664ac735ac6223d19bf567227d738f5a117ed75 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004249.txt @@ -0,0 +1 @@ +Case CASE-004249 opened 2020-03-05 re: customer CUST-01287 (delivery, WA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004250.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004250.txt new file mode 100644 index 0000000000000000000000000000000000000000..ebcd42c33b335b650fac3b3c171060e0c4a9cec9 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004250.txt @@ -0,0 +1 @@ +Case CASE-004250 opened 2020-11-09 re: customer CUST-01287 (delivery, WA). Alert type: velocity. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-004. Suspicious activity identified consistent with velocity. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004251.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004251.txt new file mode 100644 index 0000000000000000000000000000000000000000..853523b4971beb3ca5224246953d2f71327cfb5f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004251.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004251 +Opened: 2021-08-02 Investigator: INV-007 Severity: high +Customer: CUST-01287 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004252.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004252.txt new file mode 100644 index 0000000000000000000000000000000000000000..b50f8d5bbf4247e4f331a53d931158272f789eb8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004252.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004252 +Opened: 2021-11-08 Investigator: INV-001 Severity: high +Customer: CUST-01287 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004253.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004253.txt new file mode 100644 index 0000000000000000000000000000000000000000..88d8a9606d38c77c4a643f56b3a73dccc70019d3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004253.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004253 +Opened: 2021-03-16 Investigator: INV-001 Severity: high +Customer: CUST-01288 — cultivation operating in NV. + +1. BACKGROUND +The customer is a cultivation licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004254.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004254.txt new file mode 100644 index 0000000000000000000000000000000000000000..a524f4abaa1fdec71036df82f8228a894645f1c5 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004254.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004254 +Opened: 2021-11-02 Investigator: INV-002 Severity: high +Customer: CUST-01288 — cultivation operating in NV. + +1. BACKGROUND +The customer is a cultivation licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004255.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004255.txt new file mode 100644 index 0000000000000000000000000000000000000000..a160397f56588832a7009674dbbaa88c7479a01a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004255.txt @@ -0,0 +1 @@ +Case CASE-004255 opened 2019-03-18 re: customer CUST-01289 (distribution, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004256.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004256.txt new file mode 100644 index 0000000000000000000000000000000000000000..8c871fcaa0824252131dcc33fdc72b150fd6fe4e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004256.txt @@ -0,0 +1 @@ +Case CASE-004256 opened 2019-05-14 re: customer CUST-01289 (distribution, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004257.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004257.txt new file mode 100644 index 0000000000000000000000000000000000000000..2e12d1fe3723cbfefa1a607d3900cdf3cc5d87cd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004257.txt @@ -0,0 +1 @@ +Case CASE-004257 opened 2020-10-12 re: customer CUST-01289 (distribution, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-007. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004258.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004258.txt new file mode 100644 index 0000000000000000000000000000000000000000..85d9434e09358f6cdaa8dfbee62be08950f7bc64 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004258.txt @@ -0,0 +1 @@ +Case CASE-004258 opened 2020-12-14 re: customer CUST-01289 (distribution, CA). Alert type: cross_state_transfer. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004259.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004259.txt new file mode 100644 index 0000000000000000000000000000000000000000..73d8a5ace352daeb5f56c008bb8c34d439ab18ab --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004259.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004259 +Opened: 2022-05-30 Investigator: INV-005 Severity: high +Customer: CUST-01289 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004260.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004260.txt new file mode 100644 index 0000000000000000000000000000000000000000..24556389b188f3b5e6b2ab3687017a0b228adf14 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004260.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004260 +Opened: 2022-07-06 Investigator: INV-004 Severity: critical +Customer: CUST-01289 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004261.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004261.txt new file mode 100644 index 0000000000000000000000000000000000000000..cfa6126fb4bfe3393c38b36bd1e1ae3b841d54d2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004261.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004261 +Opened: 2023-01-10 Investigator: INV-006 Severity: high +Customer: CUST-01289 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004262.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004262.txt new file mode 100644 index 0000000000000000000000000000000000000000..96092c2926d1974cf98fb878b169682a21ff781b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004262.txt @@ -0,0 +1 @@ +Case CASE-004262 opened 2020-04-06 re: customer CUST-01291 (manufacturing, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004263.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004263.txt new file mode 100644 index 0000000000000000000000000000000000000000..b119bdff79caa97a0f26724a24083c52707a9ea9 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004263.txt @@ -0,0 +1 @@ +Case CASE-004263 opened 2020-06-03 re: customer CUST-01291 (manufacturing, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-006. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004264.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004264.txt new file mode 100644 index 0000000000000000000000000000000000000000..d4632628943bb2f3caa29fce6f9740472409ff05 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004264.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004264 +Opened: 2022-05-02 Investigator: INV-006 Severity: high +Customer: CUST-01291 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004265.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004265.txt new file mode 100644 index 0000000000000000000000000000000000000000..86483bfa445f0aa1816874223b682c6afbcb88a9 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004265.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004265 +Opened: 2022-08-08 Investigator: INV-008 Severity: critical +Customer: CUST-01291 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type large_cash_deposit generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004266.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004266.txt new file mode 100644 index 0000000000000000000000000000000000000000..3b86aa40e67c35eef42414403ae76a6da97407bf --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004266.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004266 +Opened: 2022-09-02 Investigator: INV-004 Severity: critical +Customer: CUST-01291 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004267.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004267.txt new file mode 100644 index 0000000000000000000000000000000000000000..4bb74e8a335832608ccc66a5523122da8e93da35 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004267.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004267 +Opened: 2024-04-17 Investigator: INV-003 Severity: critical +Customer: CUST-01291 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type geo_anomaly generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004268.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004268.txt new file mode 100644 index 0000000000000000000000000000000000000000..1ea487fb2d7e00ee51afadccf23fc299f33e18b4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004268.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004268 +Opened: 2021-12-03 Investigator: INV-002 Severity: high +Customer: CUST-01292 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004269.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004269.txt new file mode 100644 index 0000000000000000000000000000000000000000..d97c0ad8ce92e22df4283660e4895cced00c1076 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004269.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004269 +Opened: 2022-07-13 Investigator: INV-009 Severity: high +Customer: CUST-01292 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004270.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004270.txt new file mode 100644 index 0000000000000000000000000000000000000000..b5acc5e9ba7907e28aa8d1df2149629699869236 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004270.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004270 +Opened: 2024-08-26 Investigator: INV-004 Severity: high +Customer: CUST-01292 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004271.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004271.txt new file mode 100644 index 0000000000000000000000000000000000000000..ce6e71056ada5271dbba997b3ff2edfea8cdf7cf --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004271.txt @@ -0,0 +1 @@ +Case CASE-004271 opened 2019-04-10 re: customer CUST-01293 (delivery, CO). Alert type: pep_monitor. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004272.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004272.txt new file mode 100644 index 0000000000000000000000000000000000000000..7817c220eb749ce9cd6f7c4772d75dd6595e1c59 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004272.txt @@ -0,0 +1 @@ +Case CASE-004272 opened 2019-07-01 re: customer CUST-01293 (delivery, CO). Alert type: negative_news. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. Suspicious activity identified consistent with negative_news. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004273.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004273.txt new file mode 100644 index 0000000000000000000000000000000000000000..be1dc4ec231cf34cb506fd0fe6e383bc5bf8c596 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004273.txt @@ -0,0 +1 @@ +Case CASE-004273 opened 2019-08-26 re: customer CUST-01293 (delivery, CO). Alert type: pep_monitor. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. Suspicious activity identified consistent with pep_monitor. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004274.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004274.txt new file mode 100644 index 0000000000000000000000000000000000000000..3f127da028b8f871da9df1a728987c9df2773b86 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004274.txt @@ -0,0 +1 @@ +Case CASE-004274 opened 2019-10-08 re: customer CUST-01293 (delivery, CO). Alert type: pep_monitor. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. Suspicious activity identified consistent with pep_monitor. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004275.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004275.txt new file mode 100644 index 0000000000000000000000000000000000000000..e185b1d1f2561550ac1b40a9874df60d654de69f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004275.txt @@ -0,0 +1 @@ +Case CASE-004275 opened 2019-12-16 re: customer CUST-01293 (delivery, CO). Alert type: velocity. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004276.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004276.txt new file mode 100644 index 0000000000000000000000000000000000000000..90b646eda942a6f082e787b6fee3b0f54a9bc17d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004276.txt @@ -0,0 +1 @@ +Case CASE-004276 opened 2020-02-27 re: customer CUST-01293 (delivery, CO). Alert type: pep_monitor. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004277.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004277.txt new file mode 100644 index 0000000000000000000000000000000000000000..75b857277e5972082c6c3d5853748a21ec6f50e3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004277.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004277 +Opened: 2024-10-14 Investigator: INV-007 Severity: high +Customer: CUST-01294 — cultivation operating in MI. + +1. BACKGROUND +The customer is a cultivation licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004278.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004278.txt new file mode 100644 index 0000000000000000000000000000000000000000..fb52599e547a36675645787d974cd1bf4cc2e19d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004278.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004278 +Opened: 2024-11-07 Investigator: INV-003 Severity: high +Customer: CUST-01294 — cultivation operating in MI. + +1. BACKGROUND +The customer is a cultivation licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004279.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004279.txt new file mode 100644 index 0000000000000000000000000000000000000000..86af550f7434d5b0c2f804ceb0b05b87a01c8c56 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004279.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004279 +Opened: 2024-05-20 Investigator: INV-007 Severity: critical +Customer: CUST-01295 — delivery operating in NV. + +1. BACKGROUND +The customer is a delivery licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004280.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004280.txt new file mode 100644 index 0000000000000000000000000000000000000000..f57861902751fe5cb80dbc4cb187406b688b67a3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004280.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004280 +Opened: 2024-09-03 Investigator: INV-003 Severity: critical +Customer: CUST-01295 — delivery operating in NV. + +1. BACKGROUND +The customer is a delivery licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004281.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004281.txt new file mode 100644 index 0000000000000000000000000000000000000000..696f15015734a2a266700c8f364b33383927710c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004281.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004281 +Opened: 2024-10-10 Investigator: INV-008 Severity: high +Customer: CUST-01295 — delivery operating in NV. + +1. BACKGROUND +The customer is a delivery licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004282.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004282.txt new file mode 100644 index 0000000000000000000000000000000000000000..90ad76c2436a7110f1ab74fb8c4f186a0219f13c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004282.txt @@ -0,0 +1 @@ +Case CASE-004282 opened 2019-10-18 re: customer CUST-01296 (delivery, CO). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004283.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004283.txt new file mode 100644 index 0000000000000000000000000000000000000000..2a0ddfebe10fcf4e64d034d9f1375cc7b12e74fe --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004283.txt @@ -0,0 +1 @@ +Case CASE-004283 opened 2019-11-11 re: customer CUST-01296 (delivery, CO). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-002. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004284.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004284.txt new file mode 100644 index 0000000000000000000000000000000000000000..9fb105cdd44c3b9f120da57b1c3ac12100d25285 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004284.txt @@ -0,0 +1 @@ +Case CASE-004284 opened 2020-05-06 re: customer CUST-01296 (delivery, CO). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-001. Suspicious activity identified consistent with cash_threshold. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004285.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004285.txt new file mode 100644 index 0000000000000000000000000000000000000000..535b590bb8689c6cee9bec5c8bb8e4b4918e7b24 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004285.txt @@ -0,0 +1 @@ +Case CASE-004285 opened 2020-08-10 re: customer CUST-01296 (delivery, CO). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004286.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004286.txt new file mode 100644 index 0000000000000000000000000000000000000000..82b9ca7d991eca455b8573ca3c3b1066d0abe46c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004286.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004286 +Opened: 2022-10-06 Investigator: INV-009 Severity: high +Customer: CUST-01296 — delivery operating in CO. + +1. BACKGROUND +The customer is a delivery licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004287.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004287.txt new file mode 100644 index 0000000000000000000000000000000000000000..ae002cd7fd5ec68c7c96bf8ce1e52ffc24fc4e3e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004287.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004287 +Opened: 2023-04-10 Investigator: INV-010 Severity: high +Customer: CUST-01296 — delivery operating in CO. + +1. BACKGROUND +The customer is a delivery licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004288.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004288.txt new file mode 100644 index 0000000000000000000000000000000000000000..e2cd45f78eff6495d933ce8e429501dc40c21b2d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004288.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004288 +Opened: 2023-03-13 Investigator: INV-001 Severity: high +Customer: CUST-01299 — transport operating in CO. + +1. BACKGROUND +The customer is a transport licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004289.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004289.txt new file mode 100644 index 0000000000000000000000000000000000000000..577aa205eea184ea9a114cfc1828ca69f8e144e1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004289.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004289 +Opened: 2023-07-12 Investigator: INV-008 Severity: high +Customer: CUST-01299 — transport operating in CO. + +1. BACKGROUND +The customer is a transport licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004290.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004290.txt new file mode 100644 index 0000000000000000000000000000000000000000..edb32d493bc470615c82718dd27752e017488d09 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004290.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004290 +Opened: 2023-08-29 Investigator: INV-008 Severity: moderate +Customer: CUST-01299 — transport operating in CO. + +1. BACKGROUND +The customer is a transport licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004291.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004291.txt new file mode 100644 index 0000000000000000000000000000000000000000..202d5a724d41e31cc986f12175a1bef270985769 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004291.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004291 +Opened: 2023-11-13 Investigator: INV-001 Severity: high +Customer: CUST-01299 — transport operating in CO. + +1. BACKGROUND +The customer is a transport licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type wire_to_cash generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004292.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004292.txt new file mode 100644 index 0000000000000000000000000000000000000000..2f856eeed398b1dd48eb8d92142ff408fb62b1ef --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004292.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004292 +Opened: 2024-06-18 Investigator: INV-010 Severity: high +Customer: CUST-01299 — transport operating in CO. + +1. BACKGROUND +The customer is a transport licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004293.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004293.txt new file mode 100644 index 0000000000000000000000000000000000000000..96579458dcee890ec25e94d852b6db483e39854a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004293.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004293 +Opened: 2024-11-29 Investigator: INV-007 Severity: high +Customer: CUST-01299 — transport operating in CO. + +1. BACKGROUND +The customer is a transport licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004294.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004294.txt new file mode 100644 index 0000000000000000000000000000000000000000..ac82b9621cdce4d695ec3fc71e110060d78cb325 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004294.txt @@ -0,0 +1 @@ +Case CASE-004294 opened 2020-04-02 re: customer CUST-01300 (dispensary, CO). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004295.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004295.txt new file mode 100644 index 0000000000000000000000000000000000000000..b20fbd7ebe64ac883b0f02049f3b796668a5b6a3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004295.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004295 +Opened: 2021-02-02 Investigator: INV-002 Severity: high +Customer: CUST-01300 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004296.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004296.txt new file mode 100644 index 0000000000000000000000000000000000000000..94f9f5eaa1451aae3ef2dd30e83b83dd78d9a1c2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004296.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004296 +Opened: 2021-05-06 Investigator: INV-006 Severity: high +Customer: CUST-01300 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004297.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004297.txt new file mode 100644 index 0000000000000000000000000000000000000000..42f7d1c8430e7ddb06ac30216b457b8e000def67 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004297.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004297 +Opened: 2021-08-02 Investigator: INV-004 Severity: critical +Customer: CUST-01300 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004298.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004298.txt new file mode 100644 index 0000000000000000000000000000000000000000..d6f310c5fc0d8ab7ab89f44986c8076cc5dcbbc6 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004298.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004298 +Opened: 2022-08-17 Investigator: INV-003 Severity: moderate +Customer: CUST-01300 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004299.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004299.txt new file mode 100644 index 0000000000000000000000000000000000000000..91d7727a5063c092a1751503c7e956e20fd49191 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004299.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004299 +Opened: 2022-09-19 Investigator: INV-007 Severity: high +Customer: CUST-01300 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004300.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004300.txt new file mode 100644 index 0000000000000000000000000000000000000000..823f01a37befb4977379469cc1ae894d29250e0d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004300.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004300 +Opened: 2023-01-17 Investigator: INV-008 Severity: high +Customer: CUST-01301 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004301.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004301.txt new file mode 100644 index 0000000000000000000000000000000000000000..bcd390fe00c745ddec03fb52e1d284392a1e3dbf --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004301.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004301 +Opened: 2023-09-08 Investigator: INV-007 Severity: high +Customer: CUST-01301 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004302.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004302.txt new file mode 100644 index 0000000000000000000000000000000000000000..f72bf9c630a1a528b5fbe091c296239e12073703 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004302.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004302 +Opened: 2023-10-16 Investigator: INV-001 Severity: high +Customer: CUST-01301 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004303.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004303.txt new file mode 100644 index 0000000000000000000000000000000000000000..d3528dd021630640d142fb181dc596d1b34c2527 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004303.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004303 +Opened: 2024-08-14 Investigator: INV-007 Severity: critical +Customer: CUST-01301 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004304.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004304.txt new file mode 100644 index 0000000000000000000000000000000000000000..79a06341979c1960df557213617454fe08771721 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004304.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004304 +Opened: 2024-09-13 Investigator: INV-006 Severity: critical +Customer: CUST-01301 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004305.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004305.txt new file mode 100644 index 0000000000000000000000000000000000000000..4570e296313fb0dfc7629818a0b2a2bf74d7fe37 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004305.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004305 +Opened: 2024-11-11 Investigator: INV-010 Severity: high +Customer: CUST-01302 — microbusiness operating in CA. + +1. BACKGROUND +The customer is a microbusiness licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004306.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004306.txt new file mode 100644 index 0000000000000000000000000000000000000000..39f25e35bcb494f2477610bc6558108d6907777e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004306.txt @@ -0,0 +1 @@ +Case CASE-004306 opened 2020-12-11 re: customer CUST-01303 (distribution, CA). Alert type: pep_monitor. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-003. Suspicious activity identified consistent with pep_monitor. SAR filed. Severity: high. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004307.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004307.txt new file mode 100644 index 0000000000000000000000000000000000000000..a06d0aed42439233fef2eb7f2b4bca5ff80a94bb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004307.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004307 +Opened: 2021-05-18 Investigator: INV-003 Severity: high +Customer: CUST-01303 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004308.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004308.txt new file mode 100644 index 0000000000000000000000000000000000000000..2500ecbdf8d29fcc675e853f9eccc81bace956de --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004308.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004308 +Opened: 2022-03-17 Investigator: INV-001 Severity: high +Customer: CUST-01303 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004309.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004309.txt new file mode 100644 index 0000000000000000000000000000000000000000..828a3ad6ce643323cc9ad5985c6343a96c2b5b1e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004309.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004309 +Opened: 2022-08-08 Investigator: INV-009 Severity: critical +Customer: CUST-01303 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004310.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004310.txt new file mode 100644 index 0000000000000000000000000000000000000000..0274a9edd7f7498cca700b2f50e26ff3e9b74bbb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004310.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004310 +Opened: 2022-12-19 Investigator: INV-001 Severity: high +Customer: CUST-01303 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004311.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004311.txt new file mode 100644 index 0000000000000000000000000000000000000000..0fa84b58577cc5c85d1d4627e19a2987dceacff0 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004311.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004311 +Opened: 2023-02-03 Investigator: INV-009 Severity: critical +Customer: CUST-01303 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004312.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004312.txt new file mode 100644 index 0000000000000000000000000000000000000000..693a168bd0c9bee7e2cf746b26b7372e9da23131 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004312.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004312 +Opened: 2023-02-20 Investigator: INV-004 Severity: high +Customer: CUST-01303 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004313.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004313.txt new file mode 100644 index 0000000000000000000000000000000000000000..3b4330115665763476b9d63a2677702fbf7200b2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004313.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004313 +Opened: 2023-08-14 Investigator: INV-005 Severity: high +Customer: CUST-01303 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004314.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004314.txt new file mode 100644 index 0000000000000000000000000000000000000000..1da7bf74cb65d040980f732e7702b5c259e01e2d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004314.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004314 +Opened: 2024-01-02 Investigator: INV-009 Severity: high +Customer: CUST-01303 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004315.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004315.txt new file mode 100644 index 0000000000000000000000000000000000000000..b3327b316fbff33a5ed98cbd128136fc73f3c49f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004315.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004315 +Opened: 2024-03-12 Investigator: INV-006 Severity: high +Customer: CUST-01303 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004316.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004316.txt new file mode 100644 index 0000000000000000000000000000000000000000..fb08e0556a54064fdcdbfa3fbb47dd1fd2987c10 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004316.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004316 +Opened: 2024-08-06 Investigator: INV-008 Severity: high +Customer: CUST-01303 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type negative_news generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004317.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004317.txt new file mode 100644 index 0000000000000000000000000000000000000000..3e8b2985e9db7f46ec621bbc0481ee64e91dd0e5 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004317.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004317 +Opened: 2022-07-25 Investigator: INV-008 Severity: high +Customer: CUST-01304 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004318.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004318.txt new file mode 100644 index 0000000000000000000000000000000000000000..e0b0e297bd546fbf6c9db8d11271f547a908e8ec --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004318.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004318 +Opened: 2022-12-08 Investigator: INV-007 Severity: high +Customer: CUST-01304 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type new_account_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004319.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004319.txt new file mode 100644 index 0000000000000000000000000000000000000000..326a8637bc87d6f9b20d0ee99d1cf8426542e90e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004319.txt @@ -0,0 +1 @@ +Case CASE-004319 opened 2019-12-16 re: customer CUST-01305 (testing_lab, MI). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004320.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004320.txt new file mode 100644 index 0000000000000000000000000000000000000000..36a6341190b79218a29b78682ff933d558653765 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004320.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004320 +Opened: 2021-02-11 Investigator: INV-004 Severity: high +Customer: CUST-01305 — testing_lab operating in MI. + +1. BACKGROUND +The customer is a testing_lab licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004321.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004321.txt new file mode 100644 index 0000000000000000000000000000000000000000..d2a107e3a908c5ad252ee1102a6e8abc65222106 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004321.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004321 +Opened: 2021-04-19 Investigator: INV-005 Severity: critical +Customer: CUST-01305 — testing_lab operating in MI. + +1. BACKGROUND +The customer is a testing_lab licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004322.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004322.txt new file mode 100644 index 0000000000000000000000000000000000000000..bfe3dad9ceca39e8c4568a380c6b56cfea90b0b3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004322.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004322 +Opened: 2022-03-07 Investigator: INV-005 Severity: critical +Customer: CUST-01305 — testing_lab operating in MI. + +1. BACKGROUND +The customer is a testing_lab licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004323.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004323.txt new file mode 100644 index 0000000000000000000000000000000000000000..38bb9ab3b064bce639bd8b8e8a824ec1120ff781 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004323.txt @@ -0,0 +1 @@ +Case CASE-004323 opened 2020-09-02 re: customer CUST-01306 (cultivation, OR). Alert type: velocity. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004324.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004324.txt new file mode 100644 index 0000000000000000000000000000000000000000..ce94e648699e16387785b0878187242ebbf399c9 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004324.txt @@ -0,0 +1 @@ +Case CASE-004324 opened 2020-11-19 re: customer CUST-01306 (cultivation, OR). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-006. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004325.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004325.txt new file mode 100644 index 0000000000000000000000000000000000000000..18ee470073a9f72a24f286b6e9549a980e6763a6 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004325.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004325 +Opened: 2022-09-05 Investigator: INV-001 Severity: critical +Customer: CUST-01306 — cultivation operating in OR. + +1. BACKGROUND +The customer is a cultivation licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004326.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004326.txt new file mode 100644 index 0000000000000000000000000000000000000000..6152e43abfffa10773d9f4cec765e9355d865f7c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004326.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004326 +Opened: 2022-09-28 Investigator: INV-008 Severity: high +Customer: CUST-01306 — cultivation operating in OR. + +1. BACKGROUND +The customer is a cultivation licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004327.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004327.txt new file mode 100644 index 0000000000000000000000000000000000000000..58c798da030257cf5c9420f57ad5d8c720825b44 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004327.txt @@ -0,0 +1 @@ +Case CASE-004327 opened 2020-05-29 re: customer CUST-01307 (transport, WA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004328.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004328.txt new file mode 100644 index 0000000000000000000000000000000000000000..cfa24e7437745f5013a597ea165ffe087a588406 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004328.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004328 +Opened: 2021-03-08 Investigator: INV-002 Severity: high +Customer: CUST-01308 — professional_service operating in WA. + +1. BACKGROUND +The customer is a professional_service licensed in WA. At case open the point-in-time risk tier was low, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type negative_news generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004329.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004329.txt new file mode 100644 index 0000000000000000000000000000000000000000..2788a67891b19b387a83fa980128218b1fa65800 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004329.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004329 +Opened: 2022-12-05 Investigator: INV-007 Severity: high +Customer: CUST-01311 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004330.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004330.txt new file mode 100644 index 0000000000000000000000000000000000000000..2ed379c5d416342d2643e3921e47d3e055470426 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004330.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004330 +Opened: 2024-03-06 Investigator: INV-004 Severity: high +Customer: CUST-01311 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004331.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004331.txt new file mode 100644 index 0000000000000000000000000000000000000000..b4233d60ae72b8bbc14540e0969244dd68ce9094 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004331.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004331 +Opened: 2024-08-05 Investigator: INV-010 Severity: high +Customer: CUST-01311 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cannabis_wire_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004332.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004332.txt new file mode 100644 index 0000000000000000000000000000000000000000..557f42cde88bd3b76144571296b82f9e21646f16 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004332.txt @@ -0,0 +1 @@ +Case CASE-004332 opened 2019-03-04 re: customer CUST-01313 (dispensary, OR). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-002. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004333.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004333.txt new file mode 100644 index 0000000000000000000000000000000000000000..2a2817e95b1d1ee1b604276439bc9d2a8beef34e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004333.txt @@ -0,0 +1 @@ +Case CASE-004333 opened 2020-11-02 re: customer CUST-01313 (dispensary, OR). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004334.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004334.txt new file mode 100644 index 0000000000000000000000000000000000000000..cb0e11f9f93b1dff4472670b541d6bb6e23a72b2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004334.txt @@ -0,0 +1 @@ +Case CASE-004334 opened 2020-05-05 re: customer CUST-01314 (distribution, MI). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004335.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004335.txt new file mode 100644 index 0000000000000000000000000000000000000000..2fd57cd163c4316346720bd7458297c94570682b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004335.txt @@ -0,0 +1 @@ +Case CASE-004335 opened 2020-08-11 re: customer CUST-01314 (distribution, MI). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004336.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004336.txt new file mode 100644 index 0000000000000000000000000000000000000000..0b8e1f3b6456ce92fec52773349009eac453b45e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004336.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004336 +Opened: 2022-03-07 Investigator: INV-008 Severity: high +Customer: CUST-01314 — distribution operating in MI. + +1. BACKGROUND +The customer is a distribution licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004337.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004337.txt new file mode 100644 index 0000000000000000000000000000000000000000..ccda2b75ac6208b3a9750952934a753541b901e8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004337.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004337 +Opened: 2022-08-11 Investigator: INV-006 Severity: critical +Customer: CUST-01314 — distribution operating in MI. + +1. BACKGROUND +The customer is a distribution licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004338.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004338.txt new file mode 100644 index 0000000000000000000000000000000000000000..2b0a1ff3fac3d2ba3b41f7e97002f9fc46bd64e5 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004338.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004338 +Opened: 2024-05-03 Investigator: INV-003 Severity: high +Customer: CUST-01315 — dispensary operating in WA. + +1. BACKGROUND +The customer is a dispensary licensed in WA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004339.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004339.txt new file mode 100644 index 0000000000000000000000000000000000000000..06abadf366c351b4f3c35ef8eeecadf222ce3175 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004339.txt @@ -0,0 +1 @@ +Case CASE-004339 opened 2020-02-03 re: customer CUST-01316 (dispensary, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-002. Suspicious activity identified consistent with structuring. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004340.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004340.txt new file mode 100644 index 0000000000000000000000000000000000000000..bea2abe16439b8ee2ff8c440d18314854a007b2e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004340.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004340 +Opened: 2021-08-09 Investigator: INV-006 Severity: moderate +Customer: CUST-01316 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004341.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004341.txt new file mode 100644 index 0000000000000000000000000000000000000000..349e82705d318d672055af7286f924ac6bb4320d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004341.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004341 +Opened: 2021-08-27 Investigator: INV-007 Severity: critical +Customer: CUST-01316 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004342.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004342.txt new file mode 100644 index 0000000000000000000000000000000000000000..8025935059de26059ecd1eeb42af0a5f14bae59b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004342.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004342 +Opened: 2021-09-20 Investigator: INV-001 Severity: high +Customer: CUST-01316 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004343.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004343.txt new file mode 100644 index 0000000000000000000000000000000000000000..3cfa8c3cbe352d946f2b4a843b46969efbb0bd74 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004343.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004343 +Opened: 2021-12-13 Investigator: INV-001 Severity: high +Customer: CUST-01316 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004344.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004344.txt new file mode 100644 index 0000000000000000000000000000000000000000..f13808168aae864846aa008568ed201319b63120 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004344.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004344 +Opened: 2022-06-23 Investigator: INV-008 Severity: high +Customer: CUST-01316 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type negative_news generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004345.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004345.txt new file mode 100644 index 0000000000000000000000000000000000000000..5e10a63af35cf93ab2f846aa51accad0b55abf8c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004345.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004345 +Opened: 2023-02-01 Investigator: INV-007 Severity: high +Customer: CUST-01316 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004346.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004346.txt new file mode 100644 index 0000000000000000000000000000000000000000..8b38a1533de427367a7e5a91d2f62b675450b85a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004346.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004346 +Opened: 2023-12-22 Investigator: INV-009 Severity: high +Customer: CUST-01317 — transport operating in CA. + +1. BACKGROUND +The customer is a transport licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004347.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004347.txt new file mode 100644 index 0000000000000000000000000000000000000000..1142d5037d484f89ab3864e5a5fb1aa042558a8c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004347.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004347 +Opened: 2024-09-17 Investigator: INV-004 Severity: moderate +Customer: CUST-01317 — transport operating in CA. + +1. BACKGROUND +The customer is a transport licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004348.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004348.txt new file mode 100644 index 0000000000000000000000000000000000000000..01382f289225780592d6efbbbca3a3c092074315 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004348.txt @@ -0,0 +1 @@ +Case CASE-004348 opened 2019-10-03 re: customer CUST-01319 (testing_lab, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-002. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004349.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004349.txt new file mode 100644 index 0000000000000000000000000000000000000000..9c634fe7b6da1fd8e95f472bc2e61b35f4e9b9e5 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004349.txt @@ -0,0 +1 @@ +Case CASE-004349 opened 2020-05-08 re: customer CUST-01319 (testing_lab, CA). Alert type: pep_monitor. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-006. Suspicious activity identified consistent with pep_monitor. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004350.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004350.txt new file mode 100644 index 0000000000000000000000000000000000000000..4eec62648dfcc0409206c96ef23b3457049d1b9b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004350.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004350 +Opened: 2021-01-11 Investigator: INV-001 Severity: high +Customer: CUST-01319 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004351.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004351.txt new file mode 100644 index 0000000000000000000000000000000000000000..f0e9985cf65c2970b76e9de087c5b4e2565e0c48 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004351.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004351 +Opened: 2021-03-16 Investigator: INV-003 Severity: high +Customer: CUST-01319 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004352.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004352.txt new file mode 100644 index 0000000000000000000000000000000000000000..cfcbb532cd4c320ac32c3d22431d4966284c97a2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004352.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004352 +Opened: 2022-04-12 Investigator: INV-007 Severity: moderate +Customer: CUST-01319 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004353.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004353.txt new file mode 100644 index 0000000000000000000000000000000000000000..61bf950c9d9e787d3878167ee01819ad3171a99f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004353.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004353 +Opened: 2023-08-04 Investigator: INV-004 Severity: high +Customer: CUST-01319 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004354.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004354.txt new file mode 100644 index 0000000000000000000000000000000000000000..2705b27e31a47183dea24859cc4f5a1a46b7f465 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004354.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004354 +Opened: 2023-10-16 Investigator: INV-009 Severity: critical +Customer: CUST-01319 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004355.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004355.txt new file mode 100644 index 0000000000000000000000000000000000000000..4369bd2462bb7fa470daf9af0007ca3eb1604a56 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004355.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004355 +Opened: 2023-12-01 Investigator: INV-004 Severity: high +Customer: CUST-01319 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004356.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004356.txt new file mode 100644 index 0000000000000000000000000000000000000000..32a5cbeac22756413f8682c60e90bfe98d506ab6 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004356.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004356 +Opened: 2022-10-11 Investigator: INV-004 Severity: high +Customer: CUST-01320 — transport operating in MI. + +1. BACKGROUND +The customer is a transport licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004357.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004357.txt new file mode 100644 index 0000000000000000000000000000000000000000..3924a4312a6a81b3df8dc339d0e5191a4a150799 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004357.txt @@ -0,0 +1 @@ +Case CASE-004357 opened 2020-02-14 re: customer CUST-01323 (delivery, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004358.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004358.txt new file mode 100644 index 0000000000000000000000000000000000000000..9ea4fc8d7ae4e09740900d37bd5da590807be611 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004358.txt @@ -0,0 +1 @@ +Case CASE-004358 opened 2020-12-21 re: customer CUST-01323 (delivery, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-006. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004359.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004359.txt new file mode 100644 index 0000000000000000000000000000000000000000..d7a10eb52496da89e284030f838514b27688d278 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004359.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004359 +Opened: 2024-06-03 Investigator: INV-007 Severity: high +Customer: CUST-01324 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004360.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004360.txt new file mode 100644 index 0000000000000000000000000000000000000000..0df9cf6129b800108b2cc87a4fa281e88a9036ed --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004360.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004360 +Opened: 2024-09-09 Investigator: INV-007 Severity: high +Customer: CUST-01324 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004361.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004361.txt new file mode 100644 index 0000000000000000000000000000000000000000..22a8b7e851fd75baf23e98b2c75e3987596077aa --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004361.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004361 +Opened: 2024-11-07 Investigator: INV-010 Severity: high +Customer: CUST-01324 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004362.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004362.txt new file mode 100644 index 0000000000000000000000000000000000000000..3a6a11c964b34c8a84ecf2d9987d014245d4bfc2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004362.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004362 +Opened: 2021-08-09 Investigator: INV-006 Severity: high +Customer: CUST-01326 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004363.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004363.txt new file mode 100644 index 0000000000000000000000000000000000000000..ea479fbe4754bbeba1317821ae07ea4b9340fe02 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004363.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004363 +Opened: 2021-10-11 Investigator: INV-006 Severity: high +Customer: CUST-01326 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004364.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004364.txt new file mode 100644 index 0000000000000000000000000000000000000000..f499112d623684b8739deef286d5208bf32a5cd4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004364.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004364 +Opened: 2022-01-07 Investigator: INV-002 Severity: high +Customer: CUST-01326 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004365.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004365.txt new file mode 100644 index 0000000000000000000000000000000000000000..e3590c17bda8cdf1acb83defdea197906f010376 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004365.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004365 +Opened: 2022-06-06 Investigator: INV-001 Severity: high +Customer: CUST-01326 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004366.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004366.txt new file mode 100644 index 0000000000000000000000000000000000000000..2111c6c3a4a2c800caa9b24375a77a4949dce218 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004366.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004366 +Opened: 2023-02-20 Investigator: INV-010 Severity: high +Customer: CUST-01328 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004367.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004367.txt new file mode 100644 index 0000000000000000000000000000000000000000..cd7c98769388fc180ca8c17d8e5b8ea1684a763d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004367.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004367 +Opened: 2023-04-03 Investigator: INV-005 Severity: high +Customer: CUST-01328 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004368.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004368.txt new file mode 100644 index 0000000000000000000000000000000000000000..514a9ed1351f0255fce335e15e57edcc246b8495 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004368.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004368 +Opened: 2024-08-13 Investigator: INV-003 Severity: high +Customer: CUST-01328 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004369.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004369.txt new file mode 100644 index 0000000000000000000000000000000000000000..8e2cfed620ffbd714624a7b2c636f812b9c87e81 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004369.txt @@ -0,0 +1 @@ +Case CASE-004369 opened 2018-11-06 re: customer CUST-01330 (cultivation, OR). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-001. Suspicious activity identified consistent with structuring. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004370.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004370.txt new file mode 100644 index 0000000000000000000000000000000000000000..feeea547dc10f716695dfbdfeaa34424558ea7db --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004370.txt @@ -0,0 +1 @@ +Case CASE-004370 opened 2020-01-06 re: customer CUST-01331 (dispensary, NV). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004371.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004371.txt new file mode 100644 index 0000000000000000000000000000000000000000..554947ab0e0330cf348a9f6afd40f016e77ed0c5 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004371.txt @@ -0,0 +1 @@ +Case CASE-004371 opened 2020-12-07 re: customer CUST-01331 (dispensary, NV). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-006. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004372.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004372.txt new file mode 100644 index 0000000000000000000000000000000000000000..9e9806d0a530e54b945e861f9339d57d518227a1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004372.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004372 +Opened: 2021-05-07 Investigator: INV-001 Severity: high +Customer: CUST-01331 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004373.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004373.txt new file mode 100644 index 0000000000000000000000000000000000000000..d6b90defc51140b397fa6ac94c4a9cd65bd6ce82 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004373.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004373 +Opened: 2024-03-12 Investigator: INV-006 Severity: high +Customer: CUST-01333 — cultivation operating in OR. + +1. BACKGROUND +The customer is a cultivation licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004374.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004374.txt new file mode 100644 index 0000000000000000000000000000000000000000..b4b6a477cba5ce2e7c85e90dfae61a98bf671a82 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004374.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004374 +Opened: 2024-06-03 Investigator: INV-006 Severity: critical +Customer: CUST-01333 — cultivation operating in OR. + +1. BACKGROUND +The customer is a cultivation licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004375.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004375.txt new file mode 100644 index 0000000000000000000000000000000000000000..2f4c0cd40cbbd2def71a25b20a1e89dbcf05620a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004375.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004375 +Opened: 2023-10-06 Investigator: INV-003 Severity: critical +Customer: CUST-01334 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004376.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004376.txt new file mode 100644 index 0000000000000000000000000000000000000000..57677654851febb4954367440c40fa62b8b3cfbe --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004376.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004376 +Opened: 2023-12-25 Investigator: INV-006 Severity: high +Customer: CUST-01334 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004377.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004377.txt new file mode 100644 index 0000000000000000000000000000000000000000..4e369ef4913cbf05287d288787bd39aa886cd23f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004377.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004377 +Opened: 2024-05-20 Investigator: INV-001 Severity: high +Customer: CUST-01334 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004378.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004378.txt new file mode 100644 index 0000000000000000000000000000000000000000..40da23ece12c0c414a0d38facb594d52eaf388c6 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004378.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004378 +Opened: 2024-09-30 Investigator: INV-001 Severity: critical +Customer: CUST-01334 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004379.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004379.txt new file mode 100644 index 0000000000000000000000000000000000000000..d872b06033c6fe5f59bcfd7360aa3938ee79a29d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004379.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004379 +Opened: 2023-01-11 Investigator: INV-006 Severity: high +Customer: CUST-01335 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004380.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004380.txt new file mode 100644 index 0000000000000000000000000000000000000000..e395127b60232b16824b7b2a986d4173b437af1a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004380.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004380 +Opened: 2024-09-19 Investigator: INV-008 Severity: critical +Customer: CUST-01335 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004381.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004381.txt new file mode 100644 index 0000000000000000000000000000000000000000..e8d285498363da9ed7bd6c07dcadaff12f85f7d7 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004381.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004381 +Opened: 2024-10-23 Investigator: INV-003 Severity: high +Customer: CUST-01335 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004382.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004382.txt new file mode 100644 index 0000000000000000000000000000000000000000..92bc756410732fc96fd584adc784e8e86a603ff9 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004382.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004382 +Opened: 2023-06-05 Investigator: INV-008 Severity: critical +Customer: CUST-01336 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004383.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004383.txt new file mode 100644 index 0000000000000000000000000000000000000000..d6e6392e5cc1e526b6c2abafb60c3fea19092223 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004383.txt @@ -0,0 +1 @@ +Case CASE-004383 opened 2020-03-23 re: customer CUST-01337 (nursery, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004384.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004384.txt new file mode 100644 index 0000000000000000000000000000000000000000..b83761a5e07bc6e40781a3e21d90e842f872f97a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004384.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004384 +Opened: 2021-02-18 Investigator: INV-005 Severity: high +Customer: CUST-01337 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004385.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004385.txt new file mode 100644 index 0000000000000000000000000000000000000000..96b8d03265b9cb714141afdbab345145d90c4609 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004385.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004385 +Opened: 2022-12-23 Investigator: INV-007 Severity: high +Customer: CUST-01337 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004386.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004386.txt new file mode 100644 index 0000000000000000000000000000000000000000..f82af6d2949fdee9b869ca583325c7145a4fed86 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004386.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004386 +Opened: 2024-03-27 Investigator: INV-001 Severity: high +Customer: CUST-01337 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004387.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004387.txt new file mode 100644 index 0000000000000000000000000000000000000000..ef987db59ac06062ae2979c5fa1a680e0be232fe --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004387.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004387 +Opened: 2024-05-06 Investigator: INV-003 Severity: critical +Customer: CUST-01337 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004388.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004388.txt new file mode 100644 index 0000000000000000000000000000000000000000..aec51e6715d01ecf7814c9fa85b738b33d053d20 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004388.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004388 +Opened: 2023-11-06 Investigator: INV-003 Severity: high +Customer: CUST-01338 — testing_lab operating in OR. + +1. BACKGROUND +The customer is a testing_lab licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type wire_to_cash generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004389.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004389.txt new file mode 100644 index 0000000000000000000000000000000000000000..50bc438ec9c677cf37a078e84e76c4ba6840ab96 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004389.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004389 +Opened: 2024-03-06 Investigator: INV-001 Severity: critical +Customer: CUST-01338 — testing_lab operating in OR. + +1. BACKGROUND +The customer is a testing_lab licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004390.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004390.txt new file mode 100644 index 0000000000000000000000000000000000000000..2af38f18aab2ed503963986e5981d6272ad8c63f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004390.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004390 +Opened: 2024-06-12 Investigator: INV-004 Severity: high +Customer: CUST-01338 — testing_lab operating in OR. + +1. BACKGROUND +The customer is a testing_lab licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004391.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004391.txt new file mode 100644 index 0000000000000000000000000000000000000000..a00641a15d0ee00a1269428f85a3b8aec7170c1e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004391.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004391 +Opened: 2024-08-08 Investigator: INV-009 Severity: high +Customer: CUST-01338 — testing_lab operating in OR. + +1. BACKGROUND +The customer is a testing_lab licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004392.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004392.txt new file mode 100644 index 0000000000000000000000000000000000000000..e1994aa6195e99edcd7d52d46ceaf54db570f9f5 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004392.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004392 +Opened: 2024-09-11 Investigator: INV-003 Severity: high +Customer: CUST-01338 — testing_lab operating in OR. + +1. BACKGROUND +The customer is a testing_lab licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004393.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004393.txt new file mode 100644 index 0000000000000000000000000000000000000000..19b3aef4f62eac19e3ef62facc189779cdb95ed2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004393.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004393 +Opened: 2024-10-15 Investigator: INV-007 Severity: high +Customer: CUST-01338 — testing_lab operating in OR. + +1. BACKGROUND +The customer is a testing_lab licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004394.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004394.txt new file mode 100644 index 0000000000000000000000000000000000000000..144933e57607d712007b02cb8aa4614f3d4bb9a5 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004394.txt @@ -0,0 +1 @@ +Case CASE-004394 opened 2019-11-08 re: customer CUST-01339 (dispensary, NV). Alert type: high_risk_jurisdiction. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. Suspicious activity identified consistent with high_risk_jurisdiction. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004395.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004395.txt new file mode 100644 index 0000000000000000000000000000000000000000..6c43cde02d4d5c56aead3f078435f8b878cf7298 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004395.txt @@ -0,0 +1 @@ +Case CASE-004395 opened 2020-04-02 re: customer CUST-01339 (dispensary, NV). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004396.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004396.txt new file mode 100644 index 0000000000000000000000000000000000000000..760af9e6f8f12342149bc0591945bb9dfde76211 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004396.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004396 +Opened: 2023-02-13 Investigator: INV-004 Severity: high +Customer: CUST-01339 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cannabis_wire_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004397.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004397.txt new file mode 100644 index 0000000000000000000000000000000000000000..063aeaa09ac828f18ed24f9ddc24a05a6fb049aa --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004397.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004397 +Opened: 2024-02-02 Investigator: INV-008 Severity: critical +Customer: CUST-01339 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004398.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004398.txt new file mode 100644 index 0000000000000000000000000000000000000000..d90032cc48a1388718a8eb9cd2639727d6bb707d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004398.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004398 +Opened: 2023-07-17 Investigator: INV-005 Severity: critical +Customer: CUST-01340 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004399.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004399.txt new file mode 100644 index 0000000000000000000000000000000000000000..89533c03facf1d06bc6afcf121c6e66a9aa5adf7 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004399.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004399 +Opened: 2024-08-06 Investigator: INV-007 Severity: high +Customer: CUST-01341 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004400.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004400.txt new file mode 100644 index 0000000000000000000000000000000000000000..47c0292b1d230cae50c1b1988d87ffa2b5150aa1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004400.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004400 +Opened: 2021-09-09 Investigator: INV-007 Severity: critical +Customer: CUST-01342 — cultivation operating in WA. + +1. BACKGROUND +The customer is a cultivation licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004401.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004401.txt new file mode 100644 index 0000000000000000000000000000000000000000..9dfd9b428a9555c6ebb89f8a0c686b346ca4b263 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004401.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004401 +Opened: 2023-10-13 Investigator: INV-009 Severity: high +Customer: CUST-01342 — cultivation operating in WA. + +1. BACKGROUND +The customer is a cultivation licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004402.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004402.txt new file mode 100644 index 0000000000000000000000000000000000000000..4cbfd5f927f5649e46482a0f39718e58ccf4f65f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004402.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004402 +Opened: 2024-05-13 Investigator: INV-008 Severity: high +Customer: CUST-01342 — cultivation operating in WA. + +1. BACKGROUND +The customer is a cultivation licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004403.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004403.txt new file mode 100644 index 0000000000000000000000000000000000000000..3171e611e3e21e1968e00455bc38928ddcc1a707 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004403.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004403 +Opened: 2024-09-18 Investigator: INV-007 Severity: high +Customer: CUST-01342 — cultivation operating in WA. + +1. BACKGROUND +The customer is a cultivation licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004404.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004404.txt new file mode 100644 index 0000000000000000000000000000000000000000..e26ae768aa8720a4e8fe27d493697153ab4723c3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004404.txt @@ -0,0 +1 @@ +Case CASE-004404 opened 2020-08-03 re: customer CUST-01343 (dispensary, NV). Alert type: high_risk_jurisdiction. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-003. Suspicious activity identified consistent with high_risk_jurisdiction. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004405.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004405.txt new file mode 100644 index 0000000000000000000000000000000000000000..6c17daad7e0a04083b738c5c262fbd346a359ca7 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004405.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004405 +Opened: 2021-04-05 Investigator: INV-003 Severity: high +Customer: CUST-01343 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004406.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004406.txt new file mode 100644 index 0000000000000000000000000000000000000000..8666ae6cbb8e89a849c7ea1582a262e85653169b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004406.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004406 +Opened: 2022-08-05 Investigator: INV-004 Severity: critical +Customer: CUST-01343 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type negative_news generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004407.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004407.txt new file mode 100644 index 0000000000000000000000000000000000000000..fce1b0988aa0bb1a1f554dd8dae1206df09e4f70 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004407.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004407 +Opened: 2022-09-05 Investigator: INV-003 Severity: high +Customer: CUST-01343 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004408.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004408.txt new file mode 100644 index 0000000000000000000000000000000000000000..25c40a2ee73f3774b4f9c304c611cb54bf9fce24 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004408.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004408 +Opened: 2022-10-14 Investigator: INV-006 Severity: high +Customer: CUST-01343 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004409.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004409.txt new file mode 100644 index 0000000000000000000000000000000000000000..9350d7af0c370f6868179b00cc4bca8f737a19a9 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004409.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004409 +Opened: 2023-04-03 Investigator: INV-005 Severity: high +Customer: CUST-01343 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004410.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004410.txt new file mode 100644 index 0000000000000000000000000000000000000000..da64fa8e879a72d6140488317787de4706412209 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004410.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004410 +Opened: 2024-04-04 Investigator: INV-001 Severity: high +Customer: CUST-01343 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004411.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004411.txt new file mode 100644 index 0000000000000000000000000000000000000000..a421a6823eb8dcc7ea69b759ff65a2a8b8ae1d80 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004411.txt @@ -0,0 +1 @@ +Case CASE-004411 opened 2019-08-05 re: customer CUST-01344 (distribution, OR). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004412.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004412.txt new file mode 100644 index 0000000000000000000000000000000000000000..38e35cd4870f4b3450e3f7043df5591c0b5cd195 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004412.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004412 +Opened: 2022-02-15 Investigator: INV-004 Severity: high +Customer: CUST-01344 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004413.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004413.txt new file mode 100644 index 0000000000000000000000000000000000000000..4d63fe433f2800ba59f4da835c15ab3a6e2a4d0a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004413.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004413 +Opened: 2022-07-04 Investigator: INV-005 Severity: high +Customer: CUST-01344 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004414.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004414.txt new file mode 100644 index 0000000000000000000000000000000000000000..010fb06127690485574f4ddc1c9be99da73a0faf --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004414.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004414 +Opened: 2023-02-21 Investigator: INV-009 Severity: critical +Customer: CUST-01344 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004415.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004415.txt new file mode 100644 index 0000000000000000000000000000000000000000..00989dfddc48c623a09e82ea19953802ab085ab1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004415.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004415 +Opened: 2023-04-10 Investigator: INV-009 Severity: high +Customer: CUST-01344 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cannabis_wire_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004416.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004416.txt new file mode 100644 index 0000000000000000000000000000000000000000..19356c1d37627cd4f6ae2c250d0e209804a5919e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004416.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004416 +Opened: 2023-07-31 Investigator: INV-006 Severity: high +Customer: CUST-01344 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004417.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004417.txt new file mode 100644 index 0000000000000000000000000000000000000000..4684f31872e121adc3bcf582072ffc17aedb1205 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004417.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004417 +Opened: 2023-12-11 Investigator: INV-003 Severity: high +Customer: CUST-01344 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004418.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004418.txt new file mode 100644 index 0000000000000000000000000000000000000000..a86e56a08cbe4f1744aedf0519e3adfe2237a082 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004418.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004418 +Opened: 2024-02-08 Investigator: INV-001 Severity: high +Customer: CUST-01344 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004419.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004419.txt new file mode 100644 index 0000000000000000000000000000000000000000..509ed5c8a77e5927913423a153c6b8cfcf094ba6 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004419.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004419 +Opened: 2024-04-03 Investigator: INV-006 Severity: high +Customer: CUST-01344 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004420.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004420.txt new file mode 100644 index 0000000000000000000000000000000000000000..950d1a0b26436eb61384dfa655edb8aed0ba2b87 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004420.txt @@ -0,0 +1 @@ +Case CASE-004420 opened 2020-01-06 re: customer CUST-01345 (dispensary, MI). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. Suspicious activity identified consistent with structuring. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004421.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004421.txt new file mode 100644 index 0000000000000000000000000000000000000000..0ccd987e7e1fe907c8fdc424130bfcd266fb8c8c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004421.txt @@ -0,0 +1 @@ +Case CASE-004421 opened 2020-03-04 re: customer CUST-01345 (dispensary, MI). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. Suspicious activity identified consistent with cash_threshold. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004422.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004422.txt new file mode 100644 index 0000000000000000000000000000000000000000..99bc1a4209832850329c0e78dc40d975afe87c52 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004422.txt @@ -0,0 +1 @@ +Case CASE-004422 opened 2020-10-02 re: customer CUST-01345 (dispensary, MI). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-007. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004423.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004423.txt new file mode 100644 index 0000000000000000000000000000000000000000..db530058f32600b4c8dc67881ab7d9ee5e26eeac --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004423.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004423 +Opened: 2021-07-02 Investigator: INV-005 Severity: high +Customer: CUST-01345 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004424.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004424.txt new file mode 100644 index 0000000000000000000000000000000000000000..ca1314004a5d77274561581bad369249f7575973 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004424.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004424 +Opened: 2021-08-09 Investigator: INV-001 Severity: critical +Customer: CUST-01345 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004425.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004425.txt new file mode 100644 index 0000000000000000000000000000000000000000..6e2f34169f654becde968de0743da0b5b4f49b5b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004425.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004425 +Opened: 2021-02-08 Investigator: INV-003 Severity: critical +Customer: CUST-01346 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004426.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004426.txt new file mode 100644 index 0000000000000000000000000000000000000000..a85cb9e37253eac7df951171a8a36d0c2244d6cf --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004426.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004426 +Opened: 2021-07-08 Investigator: INV-007 Severity: critical +Customer: CUST-01346 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004427.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004427.txt new file mode 100644 index 0000000000000000000000000000000000000000..dd1e3cf156e0c5c22aa61fdb3462b2ba95cbabce --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004427.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004427 +Opened: 2022-07-04 Investigator: INV-009 Severity: high +Customer: CUST-01346 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004428.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004428.txt new file mode 100644 index 0000000000000000000000000000000000000000..c74a6bbe19c875a265ae296102f4734a96fb6430 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004428.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004428 +Opened: 2022-12-19 Investigator: INV-004 Severity: high +Customer: CUST-01346 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004429.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004429.txt new file mode 100644 index 0000000000000000000000000000000000000000..1ee21aacb231cde41cc559a1880bcf1e05bc2dcf --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004429.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004429 +Opened: 2024-06-12 Investigator: INV-006 Severity: high +Customer: CUST-01346 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type wire_to_cash generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004430.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004430.txt new file mode 100644 index 0000000000000000000000000000000000000000..6adee9b8c98a8e74d28e5f3944a1838d76b003c3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004430.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004430 +Opened: 2024-11-06 Investigator: INV-001 Severity: high +Customer: CUST-01346 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004431.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004431.txt new file mode 100644 index 0000000000000000000000000000000000000000..77592ab02a39089c7f4834afd5154bb260472753 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004431.txt @@ -0,0 +1 @@ +Case CASE-004431 opened 2020-11-16 re: customer CUST-01347 (manufacturing, OR). Alert type: velocity. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-006. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004432.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004432.txt new file mode 100644 index 0000000000000000000000000000000000000000..be9ee93e6ab996b937eb071256f01e168c3f25ce --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004432.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004432 +Opened: 2021-03-05 Investigator: INV-004 Severity: high +Customer: CUST-01347 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type large_cash_deposit generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004433.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004433.txt new file mode 100644 index 0000000000000000000000000000000000000000..3d9cee6130d191ca08dff516e93684f4a11a450e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004433.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004433 +Opened: 2021-08-23 Investigator: INV-004 Severity: high +Customer: CUST-01347 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004434.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004434.txt new file mode 100644 index 0000000000000000000000000000000000000000..4861b3f81d8fa300389fe4fe91254e834b2b55f1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004434.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004434 +Opened: 2021-12-06 Investigator: INV-003 Severity: critical +Customer: CUST-01347 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004435.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004435.txt new file mode 100644 index 0000000000000000000000000000000000000000..b2fb3d93ea914154551b32daca6f6280b54e80bd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004435.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004435 +Opened: 2022-01-07 Investigator: INV-006 Severity: high +Customer: CUST-01347 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type negative_news generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004436.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004436.txt new file mode 100644 index 0000000000000000000000000000000000000000..403f4eabfa304089326c129ab3165fc4bea71009 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004436.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004436 +Opened: 2022-03-16 Investigator: INV-007 Severity: high +Customer: CUST-01347 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004437.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004437.txt new file mode 100644 index 0000000000000000000000000000000000000000..b8df0866d8b78511cbab6a3c034b29d51ce32d92 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004437.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004437 +Opened: 2022-05-02 Investigator: INV-004 Severity: high +Customer: CUST-01348 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004438.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004438.txt new file mode 100644 index 0000000000000000000000000000000000000000..8f532e6e2cdc37ee94b28393bcd53bb7995685c0 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004438.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004438 +Opened: 2023-08-03 Investigator: INV-003 Severity: critical +Customer: CUST-01348 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004439.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004439.txt new file mode 100644 index 0000000000000000000000000000000000000000..6935510a9c534c950c2fa27a8cdfbfc0290b38e9 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004439.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004439 +Opened: 2023-12-04 Investigator: INV-001 Severity: critical +Customer: CUST-01348 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004440.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004440.txt new file mode 100644 index 0000000000000000000000000000000000000000..ef330290780e5ab89cabec1d23db19c92f345884 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004440.txt @@ -0,0 +1 @@ +Case CASE-004440 opened 2019-09-16 re: customer CUST-01349 (cultivation, WA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004441.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004441.txt new file mode 100644 index 0000000000000000000000000000000000000000..b10dcb4446a36ceabfed6f5552237246c9e6044d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004441.txt @@ -0,0 +1 @@ +Case CASE-004441 opened 2020-07-02 re: customer CUST-01349 (cultivation, WA). Alert type: high_risk_jurisdiction. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004442.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004442.txt new file mode 100644 index 0000000000000000000000000000000000000000..b9258ba4c57691d197130880458a2bc36494b631 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004442.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004442 +Opened: 2023-01-02 Investigator: INV-003 Severity: high +Customer: CUST-01349 — cultivation operating in WA. + +1. BACKGROUND +The customer is a cultivation licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004443.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004443.txt new file mode 100644 index 0000000000000000000000000000000000000000..2542e59a0ddb46e5af0bb517718fbb93dc738c91 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004443.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004443 +Opened: 2023-05-08 Investigator: INV-005 Severity: high +Customer: CUST-01349 — cultivation operating in WA. + +1. BACKGROUND +The customer is a cultivation licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004444.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004444.txt new file mode 100644 index 0000000000000000000000000000000000000000..37fa5bd221a7156b7457c2cf719c84130fe5dd19 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004444.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004444 +Opened: 2023-08-08 Investigator: INV-008 Severity: critical +Customer: CUST-01349 — cultivation operating in WA. + +1. BACKGROUND +The customer is a cultivation licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004445.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004445.txt new file mode 100644 index 0000000000000000000000000000000000000000..0eed08b2113389e8770340d6769e0947ee6a2936 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004445.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004445 +Opened: 2023-11-08 Investigator: INV-009 Severity: high +Customer: CUST-01349 — cultivation operating in WA. + +1. BACKGROUND +The customer is a cultivation licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004446.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004446.txt new file mode 100644 index 0000000000000000000000000000000000000000..9c30fd7e6ea722a67f79a7d9d2269186104f35ac --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004446.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004446 +Opened: 2024-05-02 Investigator: INV-001 Severity: high +Customer: CUST-01349 — cultivation operating in WA. + +1. BACKGROUND +The customer is a cultivation licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004447.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004447.txt new file mode 100644 index 0000000000000000000000000000000000000000..4efd0492635b32b21b160105b9592455d2b621ef --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004447.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004447 +Opened: 2024-11-14 Investigator: INV-009 Severity: high +Customer: CUST-01349 — cultivation operating in WA. + +1. BACKGROUND +The customer is a cultivation licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004448.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004448.txt new file mode 100644 index 0000000000000000000000000000000000000000..fe73a6dbbd568ba3dd62f204c36043a53be17475 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004448.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004448 +Opened: 2021-02-03 Investigator: INV-004 Severity: high +Customer: CUST-01350 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004449.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004449.txt new file mode 100644 index 0000000000000000000000000000000000000000..826d5a9759ad082974ab852a6fdba6da061b279b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004449.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004449 +Opened: 2023-09-18 Investigator: INV-010 Severity: high +Customer: CUST-01350 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004450.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004450.txt new file mode 100644 index 0000000000000000000000000000000000000000..31981dffecc5b9aad94346712f8df6a8cd6f73da --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004450.txt @@ -0,0 +1 @@ +Case CASE-004450 opened 2018-10-04 re: customer CUST-01351 (manufacturing, CO). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-003. Suspicious activity identified consistent with cash_threshold. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004451.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004451.txt new file mode 100644 index 0000000000000000000000000000000000000000..2ca406f592de12546f6f921d9a13c640f4462055 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004451.txt @@ -0,0 +1 @@ +Case CASE-004451 opened 2019-05-20 re: customer CUST-01351 (manufacturing, CO). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-003. Suspicious activity identified consistent with cash_threshold. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004452.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004452.txt new file mode 100644 index 0000000000000000000000000000000000000000..b67b7189dfc65d95413d83c000f5bd5f90160977 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004452.txt @@ -0,0 +1 @@ +Case CASE-004452 opened 2020-12-07 re: customer CUST-01351 (manufacturing, CO). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-007. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004453.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004453.txt new file mode 100644 index 0000000000000000000000000000000000000000..11a9f7a571c366b299d868ae62112318269bd44a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004453.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004453 +Opened: 2021-08-20 Investigator: INV-002 Severity: high +Customer: CUST-01351 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004454.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004454.txt new file mode 100644 index 0000000000000000000000000000000000000000..ffebb7af477f2487237681d34bac6be04300748e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004454.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004454 +Opened: 2021-09-20 Investigator: INV-002 Severity: high +Customer: CUST-01351 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004455.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004455.txt new file mode 100644 index 0000000000000000000000000000000000000000..f8709e25e87bd10321e1c556efa652ed2e52aec3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004455.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004455 +Opened: 2022-12-14 Investigator: INV-007 Severity: high +Customer: CUST-01351 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004456.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004456.txt new file mode 100644 index 0000000000000000000000000000000000000000..a0b6c3fa09ebdcdb6522e8e914e816e929514f03 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004456.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004456 +Opened: 2023-02-13 Investigator: INV-005 Severity: critical +Customer: CUST-01351 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004457.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004457.txt new file mode 100644 index 0000000000000000000000000000000000000000..233fce6a8807cec71c667b9a3faf51347ade57ca --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004457.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004457 +Opened: 2024-06-24 Investigator: INV-009 Severity: high +Customer: CUST-01351 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004458.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004458.txt new file mode 100644 index 0000000000000000000000000000000000000000..f9a842fa11f739e79bd82e4af8316572d01f3d0d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004458.txt @@ -0,0 +1 @@ +Case CASE-004458 opened 2019-08-20 re: customer CUST-01352 (manufacturing, WA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004459.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004459.txt new file mode 100644 index 0000000000000000000000000000000000000000..8549d9e7df739ed989b702b1e8af4305a51927cd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004459.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004459 +Opened: 2021-10-05 Investigator: INV-001 Severity: critical +Customer: CUST-01352 — manufacturing operating in WA. + +1. BACKGROUND +The customer is a manufacturing licensed in WA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004460.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004460.txt new file mode 100644 index 0000000000000000000000000000000000000000..4d0d38e95e0e8753c57c2a6da3dbb39819f734b0 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004460.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004460 +Opened: 2022-11-07 Investigator: INV-005 Severity: high +Customer: CUST-01352 — manufacturing operating in WA. + +1. BACKGROUND +The customer is a manufacturing licensed in WA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004461.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004461.txt new file mode 100644 index 0000000000000000000000000000000000000000..2ecc65138dc5e2f49afe907b1d6ceac35567d66b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004461.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004461 +Opened: 2023-01-02 Investigator: INV-003 Severity: high +Customer: CUST-01352 — manufacturing operating in WA. + +1. BACKGROUND +The customer is a manufacturing licensed in WA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004462.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004462.txt new file mode 100644 index 0000000000000000000000000000000000000000..d90459169d15f509d4ab7cf397b5745bddbeb0d6 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004462.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004462 +Opened: 2023-08-02 Investigator: INV-009 Severity: high +Customer: CUST-01352 — manufacturing operating in WA. + +1. BACKGROUND +The customer is a manufacturing licensed in WA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004463.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004463.txt new file mode 100644 index 0000000000000000000000000000000000000000..4a692a28b5587471598fc89ab0f07ac3de1c7eee --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004463.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004463 +Opened: 2023-11-06 Investigator: INV-010 Severity: high +Customer: CUST-01352 — manufacturing operating in WA. + +1. BACKGROUND +The customer is a manufacturing licensed in WA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004464.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004464.txt new file mode 100644 index 0000000000000000000000000000000000000000..0b3e8506e1591d3a4293783a53f0bc55d86653a8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004464.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004464 +Opened: 2024-04-11 Investigator: INV-004 Severity: high +Customer: CUST-01352 — manufacturing operating in WA. + +1. BACKGROUND +The customer is a manufacturing licensed in WA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004465.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004465.txt new file mode 100644 index 0000000000000000000000000000000000000000..ac073971ed11519b51df640c096ec824004551ee --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004465.txt @@ -0,0 +1 @@ +Case CASE-004465 opened 2020-05-04 re: customer CUST-01354 (distribution, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004466.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004466.txt new file mode 100644 index 0000000000000000000000000000000000000000..1cb1ea53ad0acbeae895bdec6b06d8ba08e6db6b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004466.txt @@ -0,0 +1 @@ +Case CASE-004466 opened 2020-09-09 re: customer CUST-01354 (distribution, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004467.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004467.txt new file mode 100644 index 0000000000000000000000000000000000000000..6611c70ac6e5f433da5f4f499ee6eb544138560f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004467.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004467 +Opened: 2022-08-12 Investigator: INV-007 Severity: high +Customer: CUST-01354 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004468.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004468.txt new file mode 100644 index 0000000000000000000000000000000000000000..b5fd1c7aa76e97239b7e77d8e395d10b66e12e25 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004468.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004468 +Opened: 2023-06-26 Investigator: INV-001 Severity: critical +Customer: CUST-01354 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type geo_anomaly generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004469.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004469.txt new file mode 100644 index 0000000000000000000000000000000000000000..6250114679daa7013089c341f0667668fef5eedb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004469.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004469 +Opened: 2023-08-14 Investigator: INV-006 Severity: critical +Customer: CUST-01354 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004470.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004470.txt new file mode 100644 index 0000000000000000000000000000000000000000..8c17f2e8c83d5f66b1a434c451280b743b5bf8f9 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004470.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004470 +Opened: 2023-10-06 Investigator: INV-008 Severity: high +Customer: CUST-01354 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004471.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004471.txt new file mode 100644 index 0000000000000000000000000000000000000000..513f8b3c4f001f92742f178ceefbf314d4fbca37 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004471.txt @@ -0,0 +1 @@ +Case CASE-004471 opened 2019-10-11 re: customer CUST-01355 (transport, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004472.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004472.txt new file mode 100644 index 0000000000000000000000000000000000000000..3aad9b538604b03360f71666c0fb2bbdcaece1c9 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004472.txt @@ -0,0 +1 @@ +Case CASE-004472 opened 2020-06-10 re: customer CUST-01355 (transport, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-004. Suspicious activity identified consistent with cash_threshold. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004473.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004473.txt new file mode 100644 index 0000000000000000000000000000000000000000..22216303a89a4cd91226cf9b7de935fad735aa36 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004473.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004473 +Opened: 2021-11-19 Investigator: INV-004 Severity: high +Customer: CUST-01355 — transport operating in CA. + +1. BACKGROUND +The customer is a transport licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004474.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004474.txt new file mode 100644 index 0000000000000000000000000000000000000000..26793f6106e7743e78806b120ecabdf173e34b45 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004474.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004474 +Opened: 2022-09-07 Investigator: INV-003 Severity: critical +Customer: CUST-01355 — transport operating in CA. + +1. BACKGROUND +The customer is a transport licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type geo_anomaly generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004475.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004475.txt new file mode 100644 index 0000000000000000000000000000000000000000..c2a57a7a94ae5ab9e12895100e87d7e3c9d92346 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004475.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004475 +Opened: 2022-05-10 Investigator: INV-004 Severity: critical +Customer: CUST-01356 — distribution operating in CO. + +1. BACKGROUND +The customer is a distribution licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004476.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004476.txt new file mode 100644 index 0000000000000000000000000000000000000000..2813c3d4dd05e95eeaf3ec6be48a6e2c79a454a4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004476.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004476 +Opened: 2023-01-16 Investigator: INV-008 Severity: high +Customer: CUST-01356 — distribution operating in CO. + +1. BACKGROUND +The customer is a distribution licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004477.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004477.txt new file mode 100644 index 0000000000000000000000000000000000000000..2e4e6821b323fd59eafb148434e3877572f67515 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004477.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004477 +Opened: 2024-02-19 Investigator: INV-004 Severity: critical +Customer: CUST-01356 — distribution operating in CO. + +1. BACKGROUND +The customer is a distribution licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004478.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004478.txt new file mode 100644 index 0000000000000000000000000000000000000000..68f63afc1502a64cae0f8dee583a92834c96b7b7 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004478.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004478 +Opened: 2024-04-11 Investigator: INV-001 Severity: high +Customer: CUST-01356 — distribution operating in CO. + +1. BACKGROUND +The customer is a distribution licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004479.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004479.txt new file mode 100644 index 0000000000000000000000000000000000000000..f8d24e258e3935121e34eb0702675b8e08f0b9dd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004479.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004479 +Opened: 2024-09-05 Investigator: INV-009 Severity: high +Customer: CUST-01356 — distribution operating in CO. + +1. BACKGROUND +The customer is a distribution licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004480.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004480.txt new file mode 100644 index 0000000000000000000000000000000000000000..362410e443a04237e2fc4e4422eb8dbd5aaa1676 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004480.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004480 +Opened: 2022-12-19 Investigator: INV-006 Severity: high +Customer: CUST-01357 — testing_lab operating in CO. + +1. BACKGROUND +The customer is a testing_lab licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004481.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004481.txt new file mode 100644 index 0000000000000000000000000000000000000000..cec26321453b7230122afcf5d4475d27af695e70 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004481.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004481 +Opened: 2023-02-06 Investigator: INV-009 Severity: high +Customer: CUST-01357 — testing_lab operating in CO. + +1. BACKGROUND +The customer is a testing_lab licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004482.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004482.txt new file mode 100644 index 0000000000000000000000000000000000000000..7bef91c6b4ee06cad33a3452b9863ee4c4064231 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004482.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004482 +Opened: 2023-04-20 Investigator: INV-001 Severity: high +Customer: CUST-01357 — testing_lab operating in CO. + +1. BACKGROUND +The customer is a testing_lab licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004483.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004483.txt new file mode 100644 index 0000000000000000000000000000000000000000..c61f7bca42b04686282fc975e07201112425f7d7 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004483.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004483 +Opened: 2023-08-14 Investigator: INV-006 Severity: high +Customer: CUST-01357 — testing_lab operating in CO. + +1. BACKGROUND +The customer is a testing_lab licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004484.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004484.txt new file mode 100644 index 0000000000000000000000000000000000000000..7eafb1a733374b56e0f3ef0814e2c9b40d02863d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004484.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004484 +Opened: 2023-11-21 Investigator: INV-010 Severity: high +Customer: CUST-01357 — testing_lab operating in CO. + +1. BACKGROUND +The customer is a testing_lab licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004485.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004485.txt new file mode 100644 index 0000000000000000000000000000000000000000..daeff4509c88847e6d339130fe9d0b930d84ae59 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004485.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004485 +Opened: 2024-02-05 Investigator: INV-009 Severity: high +Customer: CUST-01357 — testing_lab operating in CO. + +1. BACKGROUND +The customer is a testing_lab licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004486.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004486.txt new file mode 100644 index 0000000000000000000000000000000000000000..ce0233b8f4b3febc5b91ff2f909915ae6c7e9c7a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004486.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004486 +Opened: 2024-04-18 Investigator: INV-006 Severity: moderate +Customer: CUST-01357 — testing_lab operating in CO. + +1. BACKGROUND +The customer is a testing_lab licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004487.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004487.txt new file mode 100644 index 0000000000000000000000000000000000000000..d9425d4523d81337a48bf84848ac2c589ae5dc2b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004487.txt @@ -0,0 +1 @@ +Case CASE-004487 opened 2019-03-05 re: customer CUST-01358 (dispensary, CO). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004488.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004488.txt new file mode 100644 index 0000000000000000000000000000000000000000..ae0a36a9a55810614bcbeb498767439e91b71bd2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004488.txt @@ -0,0 +1 @@ +Case CASE-004488 opened 2019-06-03 re: customer CUST-01358 (dispensary, CO). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-002. Suspicious activity identified consistent with structuring. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004489.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004489.txt new file mode 100644 index 0000000000000000000000000000000000000000..7136ddf45482a5000605376260f7c7468a0e5085 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004489.txt @@ -0,0 +1 @@ +Case CASE-004489 opened 2020-04-02 re: customer CUST-01358 (dispensary, CO). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004490.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004490.txt new file mode 100644 index 0000000000000000000000000000000000000000..f380f7852c54b20519ac8677b58af2c457b73d27 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004490.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004490 +Opened: 2022-08-18 Investigator: INV-006 Severity: critical +Customer: CUST-01358 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004491.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004491.txt new file mode 100644 index 0000000000000000000000000000000000000000..e4f4ca2afcdbf8994e9fc524d95fd5207afb01c5 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004491.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004491 +Opened: 2022-10-07 Investigator: INV-003 Severity: critical +Customer: CUST-01358 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004492.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004492.txt new file mode 100644 index 0000000000000000000000000000000000000000..f35cc0de8759dacc047dfe8868bb9470f20d2e37 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004492.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004492 +Opened: 2023-02-06 Investigator: INV-009 Severity: high +Customer: CUST-01358 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004493.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004493.txt new file mode 100644 index 0000000000000000000000000000000000000000..cf82d538586d005658789b6c8d355ab572e03f8d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004493.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004493 +Opened: 2023-11-09 Investigator: INV-001 Severity: moderate +Customer: CUST-01358 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004494.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004494.txt new file mode 100644 index 0000000000000000000000000000000000000000..e911876c14eace1f84deca83b9e0bd315912340a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004494.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004494 +Opened: 2024-01-03 Investigator: INV-003 Severity: high +Customer: CUST-01358 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004495.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004495.txt new file mode 100644 index 0000000000000000000000000000000000000000..c6904f6018c91043be3377fe1e0faed768e5ebb5 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004495.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004495 +Opened: 2022-10-12 Investigator: INV-005 Severity: high +Customer: CUST-01359 — hemp_research operating in WA. + +1. BACKGROUND +The customer is a hemp_research licensed in WA. At case open the point-in-time risk tier was low, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004496.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004496.txt new file mode 100644 index 0000000000000000000000000000000000000000..f05ed6255cf6062c29467ac46aa31d557982572d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004496.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004496 +Opened: 2024-04-29 Investigator: INV-006 Severity: high +Customer: CUST-01359 — hemp_research operating in WA. + +1. BACKGROUND +The customer is a hemp_research licensed in WA. At case open the point-in-time risk tier was low, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004497.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004497.txt new file mode 100644 index 0000000000000000000000000000000000000000..2e6584ed86f9c5d6e32b1331cab5dd1143771acd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004497.txt @@ -0,0 +1 @@ +Case CASE-004497 opened 2019-07-02 re: customer CUST-01361 (cultivation, OR). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004498.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004498.txt new file mode 100644 index 0000000000000000000000000000000000000000..cca9a7779f5b254b8d717c502e476fd9b31cf87b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004498.txt @@ -0,0 +1 @@ +Case CASE-004498 opened 2020-12-23 re: customer CUST-01361 (cultivation, OR). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-002. Suspicious activity identified consistent with cash_threshold. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004499.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004499.txt new file mode 100644 index 0000000000000000000000000000000000000000..2a31d96fa8c1b1a94af951681eca864418294de6 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004499.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004499 +Opened: 2021-09-09 Investigator: INV-002 Severity: high +Customer: CUST-01361 — cultivation operating in OR. + +1. BACKGROUND +The customer is a cultivation licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004500.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004500.txt new file mode 100644 index 0000000000000000000000000000000000000000..0e679149b8633f20589b8a0b77ea5d7dd59f4f53 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004500.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004500 +Opened: 2022-01-10 Investigator: INV-003 Severity: critical +Customer: CUST-01361 — cultivation operating in OR. + +1. BACKGROUND +The customer is a cultivation licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004501.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004501.txt new file mode 100644 index 0000000000000000000000000000000000000000..e2df0e427792c73ca9201353c929d3fd0cd3b077 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004501.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004501 +Opened: 2022-10-07 Investigator: INV-008 Severity: high +Customer: CUST-01361 — cultivation operating in OR. + +1. BACKGROUND +The customer is a cultivation licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004502.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004502.txt new file mode 100644 index 0000000000000000000000000000000000000000..0f0ae85976b4758ad66160dbad197cdbf8f1e038 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004502.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004502 +Opened: 2022-11-22 Investigator: INV-009 Severity: critical +Customer: CUST-01361 — cultivation operating in OR. + +1. BACKGROUND +The customer is a cultivation licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004503.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004503.txt new file mode 100644 index 0000000000000000000000000000000000000000..368f015054e56c685dfa7ee69d59ae7d9b56e0cc --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004503.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004503 +Opened: 2023-05-17 Investigator: INV-007 Severity: high +Customer: CUST-01361 — cultivation operating in OR. + +1. BACKGROUND +The customer is a cultivation licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004504.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004504.txt new file mode 100644 index 0000000000000000000000000000000000000000..7d5f77dd2ea24eb2a29b775f5d0b08e8b1cf2874 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004504.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004504 +Opened: 2023-09-14 Investigator: INV-007 Severity: high +Customer: CUST-01361 — cultivation operating in OR. + +1. BACKGROUND +The customer is a cultivation licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type wire_to_cash generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004505.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004505.txt new file mode 100644 index 0000000000000000000000000000000000000000..fa469e7a3c5bbd9a94b90794d25e35cc330118f2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004505.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004505 +Opened: 2023-05-03 Investigator: INV-009 Severity: critical +Customer: CUST-01362 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cannabis_wire_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004506.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004506.txt new file mode 100644 index 0000000000000000000000000000000000000000..0dc5c100bf4dfbbdd215e9a55ce512cf34cd8ec4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004506.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004506 +Opened: 2024-01-08 Investigator: INV-006 Severity: critical +Customer: CUST-01362 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004507.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004507.txt new file mode 100644 index 0000000000000000000000000000000000000000..5385b4a060806edd16810818d06524355d8e4fc3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004507.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004507 +Opened: 2024-03-04 Investigator: INV-009 Severity: high +Customer: CUST-01362 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004508.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004508.txt new file mode 100644 index 0000000000000000000000000000000000000000..1b3b9960a62aeb313312b9e741b61f6e68a188d4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004508.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004508 +Opened: 2024-05-03 Investigator: INV-004 Severity: high +Customer: CUST-01362 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004509.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004509.txt new file mode 100644 index 0000000000000000000000000000000000000000..2962252e3d82cd2d8c739c01bab5c605f2f9ca0c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004509.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004509 +Opened: 2024-11-07 Investigator: INV-010 Severity: high +Customer: CUST-01362 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004510.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004510.txt new file mode 100644 index 0000000000000000000000000000000000000000..51686e71bf2869bb57736fbcbdc6367e29717037 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004510.txt @@ -0,0 +1 @@ +Case CASE-004510 opened 2019-06-14 re: customer CUST-01364 (microbusiness, WA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004511.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004511.txt new file mode 100644 index 0000000000000000000000000000000000000000..9f6e85444e464b9bf8dfed378e1637fa531afb45 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004511.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004511 +Opened: 2023-11-10 Investigator: INV-005 Severity: moderate +Customer: CUST-01365 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004512.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004512.txt new file mode 100644 index 0000000000000000000000000000000000000000..c900930c43b6ddc7a4c940d7664680cacd3940db --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004512.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004512 +Opened: 2024-07-02 Investigator: INV-010 Severity: high +Customer: CUST-01366 — dispensary operating in WA. + +1. BACKGROUND +The customer is a dispensary licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004513.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004513.txt new file mode 100644 index 0000000000000000000000000000000000000000..ab1b7be8df95e47ca2d0c719418e1d371e48c463 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004513.txt @@ -0,0 +1 @@ +Case CASE-004513 opened 2018-12-05 re: customer CUST-01367 (dispensary, OR). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004514.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004514.txt new file mode 100644 index 0000000000000000000000000000000000000000..648863de4ccab72ae587e35c3ffb415a34b57382 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004514.txt @@ -0,0 +1 @@ +Case CASE-004514 opened 2019-08-05 re: customer CUST-01367 (dispensary, OR). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004515.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004515.txt new file mode 100644 index 0000000000000000000000000000000000000000..49ebbbd7f27abe1d844e5f3af00c04c6b3f32011 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004515.txt @@ -0,0 +1 @@ +Case CASE-004515 opened 2020-09-02 re: customer CUST-01367 (dispensary, OR). Alert type: third_party_processor. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-003. Suspicious activity identified consistent with third_party_processor. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004516.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004516.txt new file mode 100644 index 0000000000000000000000000000000000000000..fcd3c331e6b87eda0263851dd0a1cc307aa7afcd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004516.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004516 +Opened: 2024-08-05 Investigator: INV-010 Severity: high +Customer: CUST-01367 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004517.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004517.txt new file mode 100644 index 0000000000000000000000000000000000000000..b2290b4826a576cbf4a39e6731a606744a0300c9 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004517.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004517 +Opened: 2024-10-02 Investigator: INV-010 Severity: critical +Customer: CUST-01367 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004518.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004518.txt new file mode 100644 index 0000000000000000000000000000000000000000..7276c9924fbbe5b39c3ab348f93bee12617ab506 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004518.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004518 +Opened: 2023-01-16 Investigator: INV-004 Severity: critical +Customer: CUST-01368 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004519.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004519.txt new file mode 100644 index 0000000000000000000000000000000000000000..6077d3b0ea51eb2bb74d31569bd96fb34480e8c8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004519.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004519 +Opened: 2023-04-11 Investigator: INV-004 Severity: high +Customer: CUST-01368 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004520.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004520.txt new file mode 100644 index 0000000000000000000000000000000000000000..703f8bc660c45077e5166de7cacfb08e7d0e3148 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004520.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004520 +Opened: 2023-09-04 Investigator: INV-007 Severity: high +Customer: CUST-01368 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004521.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004521.txt new file mode 100644 index 0000000000000000000000000000000000000000..e8d82349407c5ee412ff3763ad36cd23abffe50e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004521.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004521 +Opened: 2022-04-25 Investigator: INV-004 Severity: high +Customer: CUST-01369 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004522.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004522.txt new file mode 100644 index 0000000000000000000000000000000000000000..02d127be7995a701f9addb86631065ad8d1238a1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004522.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004522 +Opened: 2023-10-02 Investigator: INV-007 Severity: high +Customer: CUST-01369 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004523.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004523.txt new file mode 100644 index 0000000000000000000000000000000000000000..4cc57999d9f2402061a073edd1699e1aac78661b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004523.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004523 +Opened: 2024-07-15 Investigator: INV-006 Severity: high +Customer: CUST-01369 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004524.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004524.txt new file mode 100644 index 0000000000000000000000000000000000000000..11aae43fe46d72b4d64d460f05b1ebd760fbd6cc --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004524.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004524 +Opened: 2024-11-12 Investigator: INV-008 Severity: high +Customer: CUST-01369 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004525.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004525.txt new file mode 100644 index 0000000000000000000000000000000000000000..176b3d2059bb069a3d7ef56470fe2828263a1d86 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004525.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004525 +Opened: 2022-10-07 Investigator: INV-009 Severity: high +Customer: CUST-01370 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004526.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004526.txt new file mode 100644 index 0000000000000000000000000000000000000000..42063654ed3b39cb8d85aaac923ce1721685d5a8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004526.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004526 +Opened: 2023-04-06 Investigator: INV-005 Severity: high +Customer: CUST-01370 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004527.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004527.txt new file mode 100644 index 0000000000000000000000000000000000000000..120351c1fcdd5377497e33cb5d0e513e0c7ed98e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004527.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004527 +Opened: 2024-09-09 Investigator: INV-007 Severity: critical +Customer: CUST-01370 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004528.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004528.txt new file mode 100644 index 0000000000000000000000000000000000000000..542fe5483008937eb77b9a03f803b4e88633bc27 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004528.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004528 +Opened: 2021-11-05 Investigator: INV-007 Severity: critical +Customer: CUST-01371 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004529.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004529.txt new file mode 100644 index 0000000000000000000000000000000000000000..a62c2c88c26321bbf01b36156edfb80b853913fd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004529.txt @@ -0,0 +1 @@ +Case CASE-004529 opened 2018-09-05 re: customer CUST-01372 (microbusiness, CO). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004530.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004530.txt new file mode 100644 index 0000000000000000000000000000000000000000..80c84cd741be972328c27223f171d9cff4dc1762 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004530.txt @@ -0,0 +1 @@ +Case CASE-004530 opened 2019-07-09 re: customer CUST-01372 (microbusiness, CO). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004531.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004531.txt new file mode 100644 index 0000000000000000000000000000000000000000..8cc842dc20f02e338cd27a9fdc8ca27aa91f66a3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004531.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004531 +Opened: 2022-10-10 Investigator: INV-004 Severity: high +Customer: CUST-01372 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004532.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004532.txt new file mode 100644 index 0000000000000000000000000000000000000000..f416c10c090bace1a0bf1a8b10cb178cc26f91ff --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004532.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004532 +Opened: 2022-11-04 Investigator: INV-008 Severity: high +Customer: CUST-01372 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004533.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004533.txt new file mode 100644 index 0000000000000000000000000000000000000000..2f39911c0a73dedd6895a5edadc4624759c3c68b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004533.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004533 +Opened: 2023-08-14 Investigator: INV-009 Severity: high +Customer: CUST-01372 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004534.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004534.txt new file mode 100644 index 0000000000000000000000000000000000000000..f80f4b816948f1ede643ef0fbca437999243d283 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004534.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004534 +Opened: 2023-10-16 Investigator: INV-009 Severity: high +Customer: CUST-01372 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004535.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004535.txt new file mode 100644 index 0000000000000000000000000000000000000000..3da1a02682bc61e24297a435303582852804885a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004535.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004535 +Opened: 2023-11-08 Investigator: INV-008 Severity: high +Customer: CUST-01372 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004536.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004536.txt new file mode 100644 index 0000000000000000000000000000000000000000..5605dc9aa3816d6ee06f4432286ffbfd8e343b52 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004536.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004536 +Opened: 2021-06-03 Investigator: INV-004 Severity: high +Customer: CUST-01373 — testing_lab operating in WA. + +1. BACKGROUND +The customer is a testing_lab licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004537.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004537.txt new file mode 100644 index 0000000000000000000000000000000000000000..61221ba12af64747c672572bc801961608b54176 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004537.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004537 +Opened: 2022-06-13 Investigator: INV-003 Severity: high +Customer: CUST-01373 — testing_lab operating in WA. + +1. BACKGROUND +The customer is a testing_lab licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004538.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004538.txt new file mode 100644 index 0000000000000000000000000000000000000000..83fa20877402fdb44675ee0750e0afb69984d889 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004538.txt @@ -0,0 +1 @@ +Case CASE-004538 opened 2019-10-08 re: customer CUST-01374 (dispensary, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-005. Suspicious activity identified consistent with cash_threshold. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004539.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004539.txt new file mode 100644 index 0000000000000000000000000000000000000000..bce69b092815c69a7448734f5c9a6f3fa47ce18e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004539.txt @@ -0,0 +1 @@ +Case CASE-004539 opened 2020-01-06 re: customer CUST-01374 (dispensary, CA). Alert type: velocity. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-005. Suspicious activity identified consistent with velocity. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004540.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004540.txt new file mode 100644 index 0000000000000000000000000000000000000000..559298f8bfa9f01b031fe4a966afc72c4c5bf4db --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004540.txt @@ -0,0 +1 @@ +Case CASE-004540 opened 2020-10-05 re: customer CUST-01374 (dispensary, CA). Alert type: nighttime_activity. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-007. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004541.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004541.txt new file mode 100644 index 0000000000000000000000000000000000000000..14fd108c4bec72a6dfa6df1f733d235374848b07 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004541.txt @@ -0,0 +1 @@ +Case CASE-004541 opened 2020-11-16 re: customer CUST-01374 (dispensary, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004542.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004542.txt new file mode 100644 index 0000000000000000000000000000000000000000..b38ac093d6ea32baa229211b18eb76875fbf3beb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004542.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004542 +Opened: 2021-03-04 Investigator: INV-003 Severity: high +Customer: CUST-01374 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004543.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004543.txt new file mode 100644 index 0000000000000000000000000000000000000000..9c21c2f702eb4d73e39c9503e34f81d48039ec53 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004543.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004543 +Opened: 2021-09-07 Investigator: INV-002 Severity: critical +Customer: CUST-01374 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004544.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004544.txt new file mode 100644 index 0000000000000000000000000000000000000000..e11977c7f926a5d6977293ebab93e6051ab7687a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004544.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004544 +Opened: 2022-02-03 Investigator: INV-003 Severity: high +Customer: CUST-01374 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004545.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004545.txt new file mode 100644 index 0000000000000000000000000000000000000000..a17cad7e7bc6234e5e6d95a5c91c1aac3147f08c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004545.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004545 +Opened: 2022-08-08 Investigator: INV-003 Severity: high +Customer: CUST-01374 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004546.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004546.txt new file mode 100644 index 0000000000000000000000000000000000000000..198aa825a64930a0f08798fdd932e6879d951d62 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004546.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004546 +Opened: 2023-02-06 Investigator: INV-009 Severity: high +Customer: CUST-01374 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004547.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004547.txt new file mode 100644 index 0000000000000000000000000000000000000000..5daa2154909f6bb4feae739785c30c008285b44b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004547.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004547 +Opened: 2022-12-09 Investigator: INV-006 Severity: high +Customer: CUST-01375 — microbusiness operating in WA. + +1. BACKGROUND +The customer is a microbusiness licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004548.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004548.txt new file mode 100644 index 0000000000000000000000000000000000000000..4298a2e3c48fde06839ef8788b2375bd1f7f89ac --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004548.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004548 +Opened: 2023-02-20 Investigator: INV-003 Severity: critical +Customer: CUST-01375 — microbusiness operating in WA. + +1. BACKGROUND +The customer is a microbusiness licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004549.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004549.txt new file mode 100644 index 0000000000000000000000000000000000000000..dc8e5078ee3f2c4da29b9a32ded52a8eeae904e1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004549.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004549 +Opened: 2024-05-24 Investigator: INV-009 Severity: high +Customer: CUST-01375 — microbusiness operating in WA. + +1. BACKGROUND +The customer is a microbusiness licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type negative_news generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004550.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004550.txt new file mode 100644 index 0000000000000000000000000000000000000000..19e433fcfa11398be43bfc7729f705ff900cfa7f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004550.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004550 +Opened: 2024-08-21 Investigator: INV-001 Severity: high +Customer: CUST-01375 — microbusiness operating in WA. + +1. BACKGROUND +The customer is a microbusiness licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type negative_news generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004551.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004551.txt new file mode 100644 index 0000000000000000000000000000000000000000..6dad1e5127a5c8b0ee1abf389e84f3ff5b69d932 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004551.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004551 +Opened: 2023-07-07 Investigator: INV-009 Severity: high +Customer: CUST-01376 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004552.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004552.txt new file mode 100644 index 0000000000000000000000000000000000000000..804cbf915ee87f8f015a06277156dd6e438015b3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004552.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004552 +Opened: 2024-09-05 Investigator: INV-009 Severity: high +Customer: CUST-01376 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004553.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004553.txt new file mode 100644 index 0000000000000000000000000000000000000000..231dd57316636300bdd9af3b10292d416d7b9b35 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004553.txt @@ -0,0 +1 @@ +Case CASE-004553 opened 2020-12-04 re: customer CUST-01377 (delivery, WA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-007. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004554.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004554.txt new file mode 100644 index 0000000000000000000000000000000000000000..d7038ed1063c2ba10e08d0ad2cf0b2cdee1b3aa0 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004554.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004554 +Opened: 2021-08-04 Investigator: INV-007 Severity: critical +Customer: CUST-01377 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004555.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004555.txt new file mode 100644 index 0000000000000000000000000000000000000000..ee92efec4f376988ba92cf4b94c6a62d1990cbd3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004555.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004555 +Opened: 2021-09-06 Investigator: INV-006 Severity: high +Customer: CUST-01377 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004556.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004556.txt new file mode 100644 index 0000000000000000000000000000000000000000..66e490207264ad6073054a7b0bda84f0490f4dde --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004556.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004556 +Opened: 2022-06-02 Investigator: INV-001 Severity: high +Customer: CUST-01377 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type geo_anomaly generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004557.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004557.txt new file mode 100644 index 0000000000000000000000000000000000000000..ecbc82d15fbbf2bf99cac924618ba5a5dc2cf2af --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004557.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004557 +Opened: 2023-08-03 Investigator: INV-006 Severity: high +Customer: CUST-01377 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004558.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004558.txt new file mode 100644 index 0000000000000000000000000000000000000000..34c05d688386c2b12b0359de37da885d8d402498 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004558.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004558 +Opened: 2023-08-21 Investigator: INV-008 Severity: high +Customer: CUST-01377 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004559.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004559.txt new file mode 100644 index 0000000000000000000000000000000000000000..984a16b63f1b13821f4e8a77d2d86ded266afe6f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004559.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004559 +Opened: 2024-07-11 Investigator: INV-003 Severity: high +Customer: CUST-01377 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004560.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004560.txt new file mode 100644 index 0000000000000000000000000000000000000000..f737bf306d2b28fdb1434e21f1dc917f7eb88e21 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004560.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004560 +Opened: 2024-10-09 Investigator: INV-009 Severity: critical +Customer: CUST-01377 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004561.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004561.txt new file mode 100644 index 0000000000000000000000000000000000000000..70673b1f04ab254cf2593ede586b4911d4f59fa3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004561.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004561 +Opened: 2021-10-05 Investigator: INV-007 Severity: high +Customer: CUST-01378 — cultivation operating in MI. + +1. BACKGROUND +The customer is a cultivation licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004562.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004562.txt new file mode 100644 index 0000000000000000000000000000000000000000..624b778395e4a27bb423f753a3dcfbcb925bbc60 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004562.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004562 +Opened: 2022-02-07 Investigator: INV-004 Severity: critical +Customer: CUST-01378 — cultivation operating in MI. + +1. BACKGROUND +The customer is a cultivation licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004563.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004563.txt new file mode 100644 index 0000000000000000000000000000000000000000..096e589940fe9444f7c260320647a8c816924a52 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004563.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004563 +Opened: 2022-09-06 Investigator: INV-005 Severity: high +Customer: CUST-01378 — cultivation operating in MI. + +1. BACKGROUND +The customer is a cultivation licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004564.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004564.txt new file mode 100644 index 0000000000000000000000000000000000000000..fea4ca154c636020e0d9317bc5edb5079ed30ffb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004564.txt @@ -0,0 +1 @@ +Case CASE-004564 opened 2019-09-23 re: customer CUST-01380 (nursery, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004565.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004565.txt new file mode 100644 index 0000000000000000000000000000000000000000..ba77cd4564e9bf199d6383cb748ef1f3db7ad119 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004565.txt @@ -0,0 +1 @@ +Case CASE-004565 opened 2019-11-19 re: customer CUST-01380 (nursery, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004566.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004566.txt new file mode 100644 index 0000000000000000000000000000000000000000..3b4466e9eb3cba73d3873843127c4e9c44e6f617 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004566.txt @@ -0,0 +1 @@ +Case CASE-004566 opened 2020-10-12 re: customer CUST-01380 (nursery, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-001. Suspicious activity identified consistent with structuring. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004567.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004567.txt new file mode 100644 index 0000000000000000000000000000000000000000..9195e84536789d74c42163f6f6025b2825b0d9eb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004567.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004567 +Opened: 2021-07-05 Investigator: INV-004 Severity: high +Customer: CUST-01380 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004568.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004568.txt new file mode 100644 index 0000000000000000000000000000000000000000..b37449310b722179e2720d8a779b7c86bb5c23ac --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004568.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004568 +Opened: 2021-10-20 Investigator: INV-001 Severity: high +Customer: CUST-01380 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004569.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004569.txt new file mode 100644 index 0000000000000000000000000000000000000000..92bf84cefa7df0b37b81dea7d7d33d888c001580 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004569.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004569 +Opened: 2021-12-10 Investigator: INV-008 Severity: high +Customer: CUST-01380 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004570.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004570.txt new file mode 100644 index 0000000000000000000000000000000000000000..81fd9ae41f664ac14be285a1f3211ed2174ea2f7 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004570.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004570 +Opened: 2022-09-07 Investigator: INV-007 Severity: high +Customer: CUST-01380 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004571.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004571.txt new file mode 100644 index 0000000000000000000000000000000000000000..4728ee64ac22e3f928d449144a21a3be59d7697c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004571.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004571 +Opened: 2023-02-10 Investigator: INV-006 Severity: high +Customer: CUST-01380 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004572.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004572.txt new file mode 100644 index 0000000000000000000000000000000000000000..38bb8a1b18c59ae42df5c3bbcf0853c6fe2c1cf8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004572.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004572 +Opened: 2023-10-12 Investigator: INV-005 Severity: high +Customer: CUST-01380 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004573.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004573.txt new file mode 100644 index 0000000000000000000000000000000000000000..32181ddc99cccab2c42a40515d9b0098c50cbfc6 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004573.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004573 +Opened: 2024-08-02 Investigator: INV-006 Severity: critical +Customer: CUST-01380 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004574.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004574.txt new file mode 100644 index 0000000000000000000000000000000000000000..ad57cfbead74f47600475b4a8bb264ece90f43ab --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004574.txt @@ -0,0 +1 @@ +Case CASE-004574 opened 2019-06-03 re: customer CUST-01381 (delivery, CO). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-004. Suspicious activity identified consistent with structuring. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004575.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004575.txt new file mode 100644 index 0000000000000000000000000000000000000000..c7b43ccf90f1a5849055f4d59b08ffc86c23b5db --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004575.txt @@ -0,0 +1 @@ +Case CASE-004575 opened 2019-09-06 re: customer CUST-01381 (delivery, CO). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004576.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004576.txt new file mode 100644 index 0000000000000000000000000000000000000000..2379bf794730aafeee6fd57a7ecafdedaa6abe53 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004576.txt @@ -0,0 +1 @@ +Case CASE-004576 opened 2020-02-07 re: customer CUST-01381 (delivery, CO). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004577.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004577.txt new file mode 100644 index 0000000000000000000000000000000000000000..3adad8ddd66a5a1be688b140cc4980c3e7d16a3e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004577.txt @@ -0,0 +1 @@ +Case CASE-004577 opened 2020-05-06 re: customer CUST-01381 (delivery, CO). Alert type: structuring. 2 alert(s) reviewed. Risk tier at open: high. Investigator: INV-002. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004578.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004578.txt new file mode 100644 index 0000000000000000000000000000000000000000..a95ee289aa204336a23230a95a4ca92754ad24d6 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004578.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004578 +Opened: 2022-09-07 Investigator: INV-007 Severity: critical +Customer: CUST-01381 — delivery operating in CO. + +1. BACKGROUND +The customer is a delivery licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cannabis_wire_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004579.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004579.txt new file mode 100644 index 0000000000000000000000000000000000000000..5a495b0a1ed696b1bd750eb183124d704d104f36 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004579.txt @@ -0,0 +1 @@ +Case CASE-004579 opened 2020-05-04 re: customer CUST-01382 (manufacturing, OR). Alert type: high_risk_jurisdiction. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-005. Suspicious activity identified consistent with high_risk_jurisdiction. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004580.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004580.txt new file mode 100644 index 0000000000000000000000000000000000000000..9f2e11e6ac2f1f5bbe98e356dde9a6842e0caf0b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004580.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004580 +Opened: 2021-02-05 Investigator: INV-005 Severity: high +Customer: CUST-01382 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004581.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004581.txt new file mode 100644 index 0000000000000000000000000000000000000000..de492b3b4c7c9b1e3256bd29d802b81c6ce14ee6 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004581.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004581 +Opened: 2022-04-05 Investigator: INV-007 Severity: high +Customer: CUST-01382 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004582.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004582.txt new file mode 100644 index 0000000000000000000000000000000000000000..74e00f713110a8d7f8e6ef4888ee618a00b26ffc --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004582.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004582 +Opened: 2022-10-18 Investigator: INV-004 Severity: high +Customer: CUST-01382 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004583.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004583.txt new file mode 100644 index 0000000000000000000000000000000000000000..b4b24415870c79d99551a7e5f7681b9f1178c765 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004583.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004583 +Opened: 2022-12-05 Investigator: INV-006 Severity: high +Customer: CUST-01382 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004584.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004584.txt new file mode 100644 index 0000000000000000000000000000000000000000..7da217bf6da6499df7258a0576e1e7e4e6ea4009 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004584.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004584 +Opened: 2023-02-15 Investigator: INV-005 Severity: high +Customer: CUST-01382 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004585.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004585.txt new file mode 100644 index 0000000000000000000000000000000000000000..8321d522c52af83fe48ddac59421362feef73d20 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004585.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004585 +Opened: 2024-03-05 Investigator: INV-003 Severity: high +Customer: CUST-01384 — cultivation operating in CO. + +1. BACKGROUND +The customer is a cultivation licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004586.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004586.txt new file mode 100644 index 0000000000000000000000000000000000000000..6a017645c89872c8e025451b3a75b4103419308b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004586.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004586 +Opened: 2024-06-06 Investigator: INV-009 Severity: high +Customer: CUST-01384 — cultivation operating in CO. + +1. BACKGROUND +The customer is a cultivation licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004587.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004587.txt new file mode 100644 index 0000000000000000000000000000000000000000..23202ce1714cc33b357c5ba526ba8ee4d220229d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004587.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004587 +Opened: 2022-07-19 Investigator: INV-001 Severity: critical +Customer: CUST-01385 — microbusiness operating in CA. + +1. BACKGROUND +The customer is a microbusiness licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004588.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004588.txt new file mode 100644 index 0000000000000000000000000000000000000000..1ea7f7dfec50160bc5aeab60dd5743436e5c9a18 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004588.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004588 +Opened: 2023-02-27 Investigator: INV-010 Severity: high +Customer: CUST-01385 — microbusiness operating in CA. + +1. BACKGROUND +The customer is a microbusiness licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004589.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004589.txt new file mode 100644 index 0000000000000000000000000000000000000000..9b774d36a696e1dd95f029108bdbab445100ae5b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004589.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004589 +Opened: 2023-04-12 Investigator: INV-004 Severity: high +Customer: CUST-01385 — microbusiness operating in CA. + +1. BACKGROUND +The customer is a microbusiness licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004590.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004590.txt new file mode 100644 index 0000000000000000000000000000000000000000..6dac90c06b9ab6b29fd6274e8b62c71e23ada77d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004590.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004590 +Opened: 2023-06-13 Investigator: INV-004 Severity: critical +Customer: CUST-01385 — microbusiness operating in CA. + +1. BACKGROUND +The customer is a microbusiness licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 3 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004591.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004591.txt new file mode 100644 index 0000000000000000000000000000000000000000..a72cd5b4dc12f429c387c9bd95345124e5aa2ec9 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004591.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004591 +Opened: 2023-08-14 Investigator: INV-009 Severity: high +Customer: CUST-01385 — microbusiness operating in CA. + +1. BACKGROUND +The customer is a microbusiness licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004592.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004592.txt new file mode 100644 index 0000000000000000000000000000000000000000..12de756909b8044d07c5ae36fe57ad872ee5bc11 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004592.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004592 +Opened: 2023-12-18 Investigator: INV-006 Severity: critical +Customer: CUST-01385 — microbusiness operating in CA. + +1. BACKGROUND +The customer is a microbusiness licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004593.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004593.txt new file mode 100644 index 0000000000000000000000000000000000000000..d8cd189e68c13bc0c68e02a839809854f236342c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004593.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004593 +Opened: 2024-02-06 Investigator: INV-004 Severity: high +Customer: CUST-01385 — microbusiness operating in CA. + +1. BACKGROUND +The customer is a microbusiness licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004594.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004594.txt new file mode 100644 index 0000000000000000000000000000000000000000..55482ea5a43a699fb8481e970d1e46771fcb20c7 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004594.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004594 +Opened: 2024-05-28 Investigator: INV-008 Severity: high +Customer: CUST-01385 — microbusiness operating in CA. + +1. BACKGROUND +The customer is a microbusiness licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004595.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004595.txt new file mode 100644 index 0000000000000000000000000000000000000000..59d6c97b439e8d0d20bedab69cddd050fca737b3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004595.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004595 +Opened: 2024-09-26 Investigator: INV-006 Severity: high +Customer: CUST-01385 — microbusiness operating in CA. + +1. BACKGROUND +The customer is a microbusiness licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004596.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004596.txt new file mode 100644 index 0000000000000000000000000000000000000000..df6df8086b3811409833120e3e5871b0cae05bfe --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004596.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004596 +Opened: 2022-10-27 Investigator: INV-001 Severity: high +Customer: CUST-01386 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type negative_news generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004597.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004597.txt new file mode 100644 index 0000000000000000000000000000000000000000..9dd702847ef675adac262265a7252f90ded61a57 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004597.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004597 +Opened: 2022-11-22 Investigator: INV-004 Severity: high +Customer: CUST-01386 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004598.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004598.txt new file mode 100644 index 0000000000000000000000000000000000000000..8798c978bdc4509206fac67f1677db52de14d4f0 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004598.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004598 +Opened: 2023-01-02 Investigator: INV-001 Severity: high +Customer: CUST-01386 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004599.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004599.txt new file mode 100644 index 0000000000000000000000000000000000000000..0690883fca6f9f0a4fd9ec795a32e6207e7ce9f4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004599.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004599 +Opened: 2023-07-28 Investigator: INV-007 Severity: high +Customer: CUST-01386 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004600.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004600.txt new file mode 100644 index 0000000000000000000000000000000000000000..d07c3f5db8fad960a7a630b43c76742d4f27bae8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004600.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004600 +Opened: 2024-01-01 Investigator: INV-010 Severity: high +Customer: CUST-01386 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004601.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004601.txt new file mode 100644 index 0000000000000000000000000000000000000000..acea34967527d1435b4913a33cb9140a074002cf --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004601.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004601 +Opened: 2024-05-13 Investigator: INV-004 Severity: critical +Customer: CUST-01386 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004602.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004602.txt new file mode 100644 index 0000000000000000000000000000000000000000..fd193310e8e448b0da796c49efb6e61c63891f94 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004602.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004602 +Opened: 2024-09-18 Investigator: INV-001 Severity: critical +Customer: CUST-01386 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type new_account_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004603.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004603.txt new file mode 100644 index 0000000000000000000000000000000000000000..2ee1ec922800b68f3d64864107140255c7e57633 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004603.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004603 +Opened: 2024-11-18 Investigator: INV-009 Severity: high +Customer: CUST-01386 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004604.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004604.txt new file mode 100644 index 0000000000000000000000000000000000000000..0da45e65f944700bcc643ec055f08ef564768a78 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004604.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004604 +Opened: 2021-08-03 Investigator: INV-002 Severity: high +Customer: CUST-01387 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004605.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004605.txt new file mode 100644 index 0000000000000000000000000000000000000000..458c3898835811fde84bceb1cac4f4cdcb601512 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004605.txt @@ -0,0 +1 @@ +Case CASE-004605 opened 2019-08-28 re: customer CUST-01388 (testing_lab, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004606.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004606.txt new file mode 100644 index 0000000000000000000000000000000000000000..c5c67730e71ab502e14f970bb538b5bd03472b30 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004606.txt @@ -0,0 +1 @@ +Case CASE-004606 opened 2020-05-21 re: customer CUST-01388 (testing_lab, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004607.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004607.txt new file mode 100644 index 0000000000000000000000000000000000000000..e6eab83e416c1c19b5e73402cc065fd8639957c7 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004607.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004607 +Opened: 2022-05-27 Investigator: INV-001 Severity: high +Customer: CUST-01388 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004608.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004608.txt new file mode 100644 index 0000000000000000000000000000000000000000..ab3c466711f6e62825b712c84ee720783897531e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004608.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004608 +Opened: 2023-04-12 Investigator: INV-003 Severity: high +Customer: CUST-01388 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004609.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004609.txt new file mode 100644 index 0000000000000000000000000000000000000000..c001cfca1c40e313918b8b02415c9a77bd4c2710 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004609.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004609 +Opened: 2023-07-10 Investigator: INV-004 Severity: high +Customer: CUST-01388 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004610.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004610.txt new file mode 100644 index 0000000000000000000000000000000000000000..64a02cfa2498ba1ae3e51e2d2002dcafed5c9629 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004610.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004610 +Opened: 2023-08-03 Investigator: INV-007 Severity: high +Customer: CUST-01388 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cannabis_wire_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004611.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004611.txt new file mode 100644 index 0000000000000000000000000000000000000000..3083146d89476af8a6ec5c37281bbbd0664aea09 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004611.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004611 +Opened: 2023-12-20 Investigator: INV-001 Severity: high +Customer: CUST-01388 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004612.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004612.txt new file mode 100644 index 0000000000000000000000000000000000000000..88661845690943035d5c8f320be0e3f5517e3faf --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004612.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004612 +Opened: 2024-03-25 Investigator: INV-010 Severity: high +Customer: CUST-01388 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004613.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004613.txt new file mode 100644 index 0000000000000000000000000000000000000000..ea29f764b68ded1ad0ef27735cbd597a96354707 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004613.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004613 +Opened: 2022-07-15 Investigator: INV-009 Severity: high +Customer: CUST-01389 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004614.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004614.txt new file mode 100644 index 0000000000000000000000000000000000000000..fc9a9c2081123ce411aa36fbe78938b76d8d96b2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004614.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004614 +Opened: 2022-09-15 Investigator: INV-006 Severity: high +Customer: CUST-01389 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004615.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004615.txt new file mode 100644 index 0000000000000000000000000000000000000000..29bd5701d8576718ea1268afccda47401739662e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004615.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004615 +Opened: 2022-04-18 Investigator: INV-007 Severity: high +Customer: CUST-01390 — delivery operating in CO. + +1. BACKGROUND +The customer is a delivery licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004616.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004616.txt new file mode 100644 index 0000000000000000000000000000000000000000..b675748dd57ed6ab45d313dc5bf7d6333b21baec --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004616.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004616 +Opened: 2022-10-24 Investigator: INV-003 Severity: critical +Customer: CUST-01390 — delivery operating in CO. + +1. BACKGROUND +The customer is a delivery licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004617.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004617.txt new file mode 100644 index 0000000000000000000000000000000000000000..c1811b55e5c47f6c7cc5a56b37db2bb2575494ba --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004617.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004617 +Opened: 2023-02-20 Investigator: INV-006 Severity: high +Customer: CUST-01390 — delivery operating in CO. + +1. BACKGROUND +The customer is a delivery licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004618.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004618.txt new file mode 100644 index 0000000000000000000000000000000000000000..ca92bfd5d2299c6ef8156d5b5fd7e8279cbee3f1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004618.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004618 +Opened: 2023-10-30 Investigator: INV-009 Severity: high +Customer: CUST-01390 — delivery operating in CO. + +1. BACKGROUND +The customer is a delivery licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004619.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004619.txt new file mode 100644 index 0000000000000000000000000000000000000000..ff49220f594954b2c81521b32ef150d051263ddc --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004619.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004619 +Opened: 2024-06-13 Investigator: INV-007 Severity: high +Customer: CUST-01390 — delivery operating in CO. + +1. BACKGROUND +The customer is a delivery licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004620.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004620.txt new file mode 100644 index 0000000000000000000000000000000000000000..0875fdde7c30222c6ac2687c4ae3a23c54a48f18 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004620.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004620 +Opened: 2024-02-05 Investigator: INV-008 Severity: high +Customer: CUST-01391 — delivery operating in CO. + +1. BACKGROUND +The customer is a delivery licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004621.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004621.txt new file mode 100644 index 0000000000000000000000000000000000000000..4291076afc1595179df8e4b53d000472a7dda889 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004621.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004621 +Opened: 2024-05-07 Investigator: INV-009 Severity: high +Customer: CUST-01391 — delivery operating in CO. + +1. BACKGROUND +The customer is a delivery licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004622.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004622.txt new file mode 100644 index 0000000000000000000000000000000000000000..01136f7c2f3c2659fa6036e7b710e36f084dda5b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004622.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004622 +Opened: 2024-09-20 Investigator: INV-001 Severity: high +Customer: CUST-01391 — delivery operating in CO. + +1. BACKGROUND +The customer is a delivery licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004623.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004623.txt new file mode 100644 index 0000000000000000000000000000000000000000..9d949435ac44245ce9b68ec0f36a336062fc86b4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004623.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004623 +Opened: 2024-11-07 Investigator: INV-001 Severity: critical +Customer: CUST-01391 — delivery operating in CO. + +1. BACKGROUND +The customer is a delivery licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004624.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004624.txt new file mode 100644 index 0000000000000000000000000000000000000000..fbaad9b5a777e17cb3a7630d413e28dc39657f8d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004624.txt @@ -0,0 +1 @@ +Case CASE-004624 opened 2019-07-11 re: customer CUST-01392 (dispensary, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004625.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004625.txt new file mode 100644 index 0000000000000000000000000000000000000000..d012dc040225c1fbc53b918d242b3a3598c30ce3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004625.txt @@ -0,0 +1 @@ +Case CASE-004625 opened 2020-02-03 re: customer CUST-01392 (dispensary, CA). Alert type: high_risk_jurisdiction. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-001. Suspicious activity identified consistent with high_risk_jurisdiction. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004626.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004626.txt new file mode 100644 index 0000000000000000000000000000000000000000..37128c604541f68e14068e096463bff3c5a30ae4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004626.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004626 +Opened: 2022-06-13 Investigator: INV-001 Severity: high +Customer: CUST-01392 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004627.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004627.txt new file mode 100644 index 0000000000000000000000000000000000000000..aea3474b4afc7aa6d4be220507fd24639bf9433e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004627.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004627 +Opened: 2022-08-05 Investigator: INV-001 Severity: high +Customer: CUST-01392 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004628.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004628.txt new file mode 100644 index 0000000000000000000000000000000000000000..137cd278f4cc6d22ed3c09ac1eeaec44fa607790 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004628.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004628 +Opened: 2023-05-04 Investigator: INV-005 Severity: high +Customer: CUST-01392 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004629.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004629.txt new file mode 100644 index 0000000000000000000000000000000000000000..ea45075675038ff9fcd0078101fb7107b3743aae --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004629.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004629 +Opened: 2023-11-02 Investigator: INV-008 Severity: critical +Customer: CUST-01392 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004630.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004630.txt new file mode 100644 index 0000000000000000000000000000000000000000..ae2c8cd203c1fe4f18b20d1cf93255dc328aee07 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004630.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004630 +Opened: 2024-04-10 Investigator: INV-001 Severity: high +Customer: CUST-01392 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004631.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004631.txt new file mode 100644 index 0000000000000000000000000000000000000000..0998c9d3ce157b7e7c59a7257a0103b9a8f3d2ce --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004631.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004631 +Opened: 2024-09-02 Investigator: INV-001 Severity: high +Customer: CUST-01392 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cannabis_wire_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004632.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004632.txt new file mode 100644 index 0000000000000000000000000000000000000000..fbbb2f0179ebb2f05b10d40673de39ec90706b52 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004632.txt @@ -0,0 +1 @@ +Case CASE-004632 opened 2020-07-03 re: customer CUST-01393 (dispensary, OR). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-006. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004633.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004633.txt new file mode 100644 index 0000000000000000000000000000000000000000..910136a5831c1825459fa73c3f4fad88daf5a16d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004633.txt @@ -0,0 +1 @@ +Case CASE-004633 opened 2020-11-06 re: customer CUST-01393 (dispensary, OR). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-007. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004634.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004634.txt new file mode 100644 index 0000000000000000000000000000000000000000..0605380561f85296e686534ab40fc3131d164041 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004634.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004634 +Opened: 2021-06-02 Investigator: INV-003 Severity: high +Customer: CUST-01393 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004635.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004635.txt new file mode 100644 index 0000000000000000000000000000000000000000..1687b7da96f2e7ff71aeaf1e1ec28ab424850108 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004635.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004635 +Opened: 2021-11-08 Investigator: INV-001 Severity: high +Customer: CUST-01393 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004636.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004636.txt new file mode 100644 index 0000000000000000000000000000000000000000..d903ab16af2b7e837bcc279f470dd560d6f9d838 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004636.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004636 +Opened: 2023-12-04 Investigator: INV-001 Severity: high +Customer: CUST-01393 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004637.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004637.txt new file mode 100644 index 0000000000000000000000000000000000000000..338b4a815fa5955ad7aea5f35673ee6c81acfc34 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004637.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004637 +Opened: 2022-03-07 Investigator: INV-004 Severity: high +Customer: CUST-01394 — distribution operating in CO. + +1. BACKGROUND +The customer is a distribution licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004638.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004638.txt new file mode 100644 index 0000000000000000000000000000000000000000..9f8ddde4afccb069a078f20e81a9d2cc356315db --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004638.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004638 +Opened: 2022-10-17 Investigator: INV-009 Severity: high +Customer: CUST-01394 — distribution operating in CO. + +1. BACKGROUND +The customer is a distribution licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004639.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004639.txt new file mode 100644 index 0000000000000000000000000000000000000000..29ba3cb48c34b110713e711d4de1eff6846d8e71 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004639.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004639 +Opened: 2022-02-02 Investigator: INV-004 Severity: high +Customer: CUST-01395 — distribution operating in MI. + +1. BACKGROUND +The customer is a distribution licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004640.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004640.txt new file mode 100644 index 0000000000000000000000000000000000000000..22dd3da9be10827d20af587ae721398fe3d86a61 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004640.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004640 +Opened: 2022-09-12 Investigator: INV-005 Severity: high +Customer: CUST-01395 — distribution operating in MI. + +1. BACKGROUND +The customer is a distribution licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004641.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004641.txt new file mode 100644 index 0000000000000000000000000000000000000000..2a166c2733c363605df4f4ae678243df5c6aba60 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004641.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004641 +Opened: 2023-02-15 Investigator: INV-010 Severity: high +Customer: CUST-01395 — distribution operating in MI. + +1. BACKGROUND +The customer is a distribution licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004642.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004642.txt new file mode 100644 index 0000000000000000000000000000000000000000..74aa465cf3516b45cb23c4f4c6000541af3d331e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004642.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004642 +Opened: 2023-03-02 Investigator: INV-010 Severity: high +Customer: CUST-01395 — distribution operating in MI. + +1. BACKGROUND +The customer is a distribution licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004643.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004643.txt new file mode 100644 index 0000000000000000000000000000000000000000..4a14af1c9729288330635ceb5ed6bb08e0ca8646 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004643.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004643 +Opened: 2023-05-16 Investigator: INV-009 Severity: high +Customer: CUST-01395 — distribution operating in MI. + +1. BACKGROUND +The customer is a distribution licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004644.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004644.txt new file mode 100644 index 0000000000000000000000000000000000000000..1fccaf40f4bc2c1143e7f199b161258ca7be3274 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004644.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004644 +Opened: 2023-06-02 Investigator: INV-006 Severity: high +Customer: CUST-01395 — distribution operating in MI. + +1. BACKGROUND +The customer is a distribution licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004645.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004645.txt new file mode 100644 index 0000000000000000000000000000000000000000..423a0142b6bc5ea59e1e3f705c6262ccb34aa7e0 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004645.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004645 +Opened: 2023-12-19 Investigator: INV-004 Severity: high +Customer: CUST-01395 — distribution operating in MI. + +1. BACKGROUND +The customer is a distribution licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004646.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004646.txt new file mode 100644 index 0000000000000000000000000000000000000000..895f2b8a1cfedbfeec49912ded5d3131bf613d7c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004646.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004646 +Opened: 2024-07-03 Investigator: INV-006 Severity: high +Customer: CUST-01395 — distribution operating in MI. + +1. BACKGROUND +The customer is a distribution licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004647.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004647.txt new file mode 100644 index 0000000000000000000000000000000000000000..c08f513862fb6b400e8d120d51993ba41c2784ce --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004647.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004647 +Opened: 2021-05-11 Investigator: INV-002 Severity: high +Customer: CUST-01396 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004648.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004648.txt new file mode 100644 index 0000000000000000000000000000000000000000..797e0ddf8ddf304e74dd75509079f0006bc8fe27 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004648.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004648 +Opened: 2021-09-03 Investigator: INV-004 Severity: high +Customer: CUST-01396 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004649.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004649.txt new file mode 100644 index 0000000000000000000000000000000000000000..aa58a523566115d2cc882e6efe3bf1541b4ad0ec --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004649.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004649 +Opened: 2022-07-11 Investigator: INV-006 Severity: high +Customer: CUST-01396 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004650.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004650.txt new file mode 100644 index 0000000000000000000000000000000000000000..c39879faf84620177d18763ab82022eb25dc3a80 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004650.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004650 +Opened: 2023-12-06 Investigator: INV-007 Severity: high +Customer: CUST-01396 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004651.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004651.txt new file mode 100644 index 0000000000000000000000000000000000000000..734cf369e9c657660415b0dbe8e36181814b3dd3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004651.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004651 +Opened: 2024-08-19 Investigator: INV-009 Severity: high +Customer: CUST-01396 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004652.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004652.txt new file mode 100644 index 0000000000000000000000000000000000000000..3610acaa028e74b7f7543c8fdc14d6b4e6f6a3cb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004652.txt @@ -0,0 +1 @@ +Case CASE-004652 opened 2020-01-27 re: customer CUST-01398 (testing_lab, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-004. Suspicious activity identified consistent with cash_threshold. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004653.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004653.txt new file mode 100644 index 0000000000000000000000000000000000000000..71689881a3ba61ef59e91c529622a5bf2a8106c1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004653.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004653 +Opened: 2023-02-14 Investigator: INV-003 Severity: high +Customer: CUST-01398 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cannabis_wire_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004654.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004654.txt new file mode 100644 index 0000000000000000000000000000000000000000..240fe2fc9a5e7d8f0de66773855a69a81cca6ade --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004654.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004654 +Opened: 2023-08-30 Investigator: INV-007 Severity: high +Customer: CUST-01398 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004655.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004655.txt new file mode 100644 index 0000000000000000000000000000000000000000..a6fb2da6f69d6d498f23b7e89baefa858d6b916a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004655.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004655 +Opened: 2023-09-20 Investigator: INV-008 Severity: moderate +Customer: CUST-01398 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004656.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004656.txt new file mode 100644 index 0000000000000000000000000000000000000000..047aca897e372f79bf9b1642b762fe010be2c739 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004656.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004656 +Opened: 2022-05-10 Investigator: INV-009 Severity: high +Customer: CUST-01399 — microbusiness operating in OR. + +1. BACKGROUND +The customer is a microbusiness licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type geo_anomaly generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004657.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004657.txt new file mode 100644 index 0000000000000000000000000000000000000000..ea3901c24a009717c6fcc100ed457c63cc5f8597 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004657.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004657 +Opened: 2023-07-10 Investigator: INV-006 Severity: high +Customer: CUST-01399 — microbusiness operating in OR. + +1. BACKGROUND +The customer is a microbusiness licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004658.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004658.txt new file mode 100644 index 0000000000000000000000000000000000000000..47be8f78a1bf48dfc27326b1f92d959dac17bfe6 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004658.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004658 +Opened: 2023-08-07 Investigator: INV-001 Severity: critical +Customer: CUST-01399 — microbusiness operating in OR. + +1. BACKGROUND +The customer is a microbusiness licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004659.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004659.txt new file mode 100644 index 0000000000000000000000000000000000000000..2bb0166dce9e62fc908d3ab01787c7c203c0e668 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004659.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004659 +Opened: 2024-03-13 Investigator: INV-004 Severity: high +Customer: CUST-01399 — microbusiness operating in OR. + +1. BACKGROUND +The customer is a microbusiness licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004660.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004660.txt new file mode 100644 index 0000000000000000000000000000000000000000..3ae6e5d8ab7a46a716d569f4a749b33bc00a8246 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004660.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004660 +Opened: 2024-04-08 Investigator: INV-010 Severity: high +Customer: CUST-01399 — microbusiness operating in OR. + +1. BACKGROUND +The customer is a microbusiness licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004661.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004661.txt new file mode 100644 index 0000000000000000000000000000000000000000..416692197ddddc977dc6a7b7944758a49d7694c9 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004661.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004661 +Opened: 2024-11-04 Investigator: INV-001 Severity: critical +Customer: CUST-01399 — microbusiness operating in OR. + +1. BACKGROUND +The customer is a microbusiness licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004662.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004662.txt new file mode 100644 index 0000000000000000000000000000000000000000..7a0370701a1d85a212ae95b581b5929fc275d93f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004662.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004662 +Opened: 2022-04-04 Investigator: INV-001 Severity: high +Customer: CUST-01400 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004663.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004663.txt new file mode 100644 index 0000000000000000000000000000000000000000..4572954b36f26da734e907337f0a7c9fe89c6faf --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004663.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004663 +Opened: 2024-08-12 Investigator: INV-008 Severity: high +Customer: CUST-01403 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004664.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004664.txt new file mode 100644 index 0000000000000000000000000000000000000000..235e10dde89dd24ee1a1fd7341d5aebcf453999d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004664.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004664 +Opened: 2024-09-16 Investigator: INV-010 Severity: high +Customer: CUST-01403 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004665.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004665.txt new file mode 100644 index 0000000000000000000000000000000000000000..5aea5fef86b68d528049764dc8fb182b83a4e564 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004665.txt @@ -0,0 +1 @@ +Case CASE-004665 opened 2019-10-09 re: customer CUST-01404 (manufacturing, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-003. Suspicious activity identified consistent with cash_threshold. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004666.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004666.txt new file mode 100644 index 0000000000000000000000000000000000000000..56b4153a6d37c7897361b649185f0ed51b5a4a2d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004666.txt @@ -0,0 +1 @@ +Case CASE-004666 opened 2019-11-06 re: customer CUST-01404 (manufacturing, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004667.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004667.txt new file mode 100644 index 0000000000000000000000000000000000000000..6321bcb75a5978ebbeedef588137c5e93a3845e8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004667.txt @@ -0,0 +1 @@ +Case CASE-004667 opened 2020-06-09 re: customer CUST-01404 (manufacturing, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-002. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004668.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004668.txt new file mode 100644 index 0000000000000000000000000000000000000000..59bae920af42f1e8ce6c9a077e8314931ebb9957 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004668.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004668 +Opened: 2021-01-04 Investigator: INV-005 Severity: critical +Customer: CUST-01404 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004669.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004669.txt new file mode 100644 index 0000000000000000000000000000000000000000..43db1279eef163e57ffab03cc0003a4dc018f128 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004669.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004669 +Opened: 2021-03-15 Investigator: INV-002 Severity: high +Customer: CUST-01404 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004670.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004670.txt new file mode 100644 index 0000000000000000000000000000000000000000..703d8e208249f8c2f6f30420e625acc73ad57dd8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004670.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004670 +Opened: 2021-09-20 Investigator: INV-005 Severity: critical +Customer: CUST-01404 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004671.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004671.txt new file mode 100644 index 0000000000000000000000000000000000000000..262d00782f31754015d73de2b4efd38b5d1ed178 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004671.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004671 +Opened: 2022-01-07 Investigator: INV-008 Severity: high +Customer: CUST-01404 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004672.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004672.txt new file mode 100644 index 0000000000000000000000000000000000000000..8462641e8a93389cc9144776febbb34474c858eb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004672.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004672 +Opened: 2022-04-18 Investigator: INV-004 Severity: high +Customer: CUST-01404 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004673.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004673.txt new file mode 100644 index 0000000000000000000000000000000000000000..7723fc8e1afdda0b8fd24d77c28d71a9fd979487 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004673.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004673 +Opened: 2023-02-24 Investigator: INV-006 Severity: high +Customer: CUST-01404 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004674.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004674.txt new file mode 100644 index 0000000000000000000000000000000000000000..547011e54c8111fe09322a4a60bb805e28969793 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004674.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004674 +Opened: 2023-04-07 Investigator: INV-006 Severity: critical +Customer: CUST-01404 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004675.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004675.txt new file mode 100644 index 0000000000000000000000000000000000000000..378cabd901e966b60dfa6062ac17475ff18fb75a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004675.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004675 +Opened: 2023-11-06 Investigator: INV-005 Severity: high +Customer: CUST-01404 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004676.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004676.txt new file mode 100644 index 0000000000000000000000000000000000000000..05035865c2158cfb16ad145377c6a4422db639f0 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004676.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004676 +Opened: 2024-10-30 Investigator: INV-008 Severity: high +Customer: CUST-01405 — event_organizer operating in MI. + +1. BACKGROUND +The customer is a event_organizer licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004677.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004677.txt new file mode 100644 index 0000000000000000000000000000000000000000..8eb0bb091d60efd58f2741ecc3aae5d3158ef81e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004677.txt @@ -0,0 +1 @@ +Case CASE-004677 opened 2020-03-18 re: customer CUST-01406 (transport, WA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-004. Suspicious activity identified consistent with structuring. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004678.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004678.txt new file mode 100644 index 0000000000000000000000000000000000000000..4d86f3624097c0ccff7b86f4ee9a2a9e84407094 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004678.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004678 +Opened: 2021-10-25 Investigator: INV-005 Severity: high +Customer: CUST-01406 — transport operating in WA. + +1. BACKGROUND +The customer is a transport licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004679.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004679.txt new file mode 100644 index 0000000000000000000000000000000000000000..f26acd718f310dee8df21ccdcc2852d1d88f59ad --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004679.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004679 +Opened: 2022-08-23 Investigator: INV-004 Severity: moderate +Customer: CUST-01406 — transport operating in WA. + +1. BACKGROUND +The customer is a transport licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004680.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004680.txt new file mode 100644 index 0000000000000000000000000000000000000000..2b3bd717c038c0fb34f91e910386429eb6fa346f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004680.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004680 +Opened: 2023-04-13 Investigator: INV-003 Severity: high +Customer: CUST-01406 — transport operating in WA. + +1. BACKGROUND +The customer is a transport licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cannabis_wire_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004681.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004681.txt new file mode 100644 index 0000000000000000000000000000000000000000..c90c9da05e876fab42880d7e5493a703cbdf4775 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004681.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004681 +Opened: 2024-08-30 Investigator: INV-009 Severity: high +Customer: CUST-01406 — transport operating in WA. + +1. BACKGROUND +The customer is a transport licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004682.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004682.txt new file mode 100644 index 0000000000000000000000000000000000000000..2dbb00ba4f088288372dfa88c18fd3316e7df179 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004682.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004682 +Opened: 2022-07-08 Investigator: INV-009 Severity: high +Customer: CUST-01408 — testing_lab operating in MI. + +1. BACKGROUND +The customer is a testing_lab licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004683.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004683.txt new file mode 100644 index 0000000000000000000000000000000000000000..577d135db90fcad7cbb546f776d934a06a2a1242 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004683.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004683 +Opened: 2023-03-06 Investigator: INV-003 Severity: high +Customer: CUST-01408 — testing_lab operating in MI. + +1. BACKGROUND +The customer is a testing_lab licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004684.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004684.txt new file mode 100644 index 0000000000000000000000000000000000000000..1903298f444e4a81e3e1b99aa1c6afeafc3f2097 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004684.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004684 +Opened: 2023-05-05 Investigator: INV-006 Severity: high +Customer: CUST-01408 — testing_lab operating in MI. + +1. BACKGROUND +The customer is a testing_lab licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004685.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004685.txt new file mode 100644 index 0000000000000000000000000000000000000000..aab8f8c0b25002289015ec24395e1c3e556d32b6 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004685.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004685 +Opened: 2023-08-29 Investigator: INV-009 Severity: high +Customer: CUST-01408 — testing_lab operating in MI. + +1. BACKGROUND +The customer is a testing_lab licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004686.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004686.txt new file mode 100644 index 0000000000000000000000000000000000000000..26e76eb71bceee1aad2b3c289dd62113e1c15bb5 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004686.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004686 +Opened: 2024-08-05 Investigator: INV-001 Severity: critical +Customer: CUST-01408 — testing_lab operating in MI. + +1. BACKGROUND +The customer is a testing_lab licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004687.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004687.txt new file mode 100644 index 0000000000000000000000000000000000000000..45491e1489c6b8973223bded4d449eeb6b47db20 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004687.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004687 +Opened: 2024-10-09 Investigator: INV-004 Severity: critical +Customer: CUST-01408 — testing_lab operating in MI. + +1. BACKGROUND +The customer is a testing_lab licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004688.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004688.txt new file mode 100644 index 0000000000000000000000000000000000000000..4d64330532549f553413f92d295076c4e0c35be4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004688.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004688 +Opened: 2022-04-11 Investigator: INV-001 Severity: critical +Customer: CUST-01410 — delivery operating in CO. + +1. BACKGROUND +The customer is a delivery licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004689.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004689.txt new file mode 100644 index 0000000000000000000000000000000000000000..57de5ed685bdee27c4aa1fc2e788f63d0342cd6e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004689.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004689 +Opened: 2022-07-06 Investigator: INV-003 Severity: high +Customer: CUST-01410 — delivery operating in CO. + +1. BACKGROUND +The customer is a delivery licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004690.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004690.txt new file mode 100644 index 0000000000000000000000000000000000000000..623d0cf37a774803662def5056f3ccabbcbe5715 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004690.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004690 +Opened: 2023-10-03 Investigator: INV-006 Severity: critical +Customer: CUST-01410 — delivery operating in CO. + +1. BACKGROUND +The customer is a delivery licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004691.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004691.txt new file mode 100644 index 0000000000000000000000000000000000000000..a3ca4090a698b80b597acc4d340b97e42a5edb38 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004691.txt @@ -0,0 +1 @@ +Case CASE-004691 opened 2018-03-05 re: customer CUST-01411 (dispensary, MI). Alert type: high_risk_jurisdiction. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004692.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004692.txt new file mode 100644 index 0000000000000000000000000000000000000000..a978cdbf78dcdcef0a9a5db64a92ac21fc5cd201 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004692.txt @@ -0,0 +1 @@ +Case CASE-004692 opened 2019-03-04 re: customer CUST-01411 (dispensary, MI). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-002. Suspicious activity identified consistent with structuring. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004693.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004693.txt new file mode 100644 index 0000000000000000000000000000000000000000..18c2ae3688bce635ee0507185dd4831010b9734a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004693.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004693 +Opened: 2021-02-02 Investigator: INV-002 Severity: high +Customer: CUST-01411 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004694.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004694.txt new file mode 100644 index 0000000000000000000000000000000000000000..0539be3e7dc2671eeddff0cb81981df800e0d891 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004694.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004694 +Opened: 2021-10-11 Investigator: INV-005 Severity: high +Customer: CUST-01411 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004695.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004695.txt new file mode 100644 index 0000000000000000000000000000000000000000..fc026e9688ca861a37617b0574cde6a9fcddb489 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004695.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004695 +Opened: 2023-09-05 Investigator: INV-001 Severity: high +Customer: CUST-01411 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004696.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004696.txt new file mode 100644 index 0000000000000000000000000000000000000000..31ae12da812e799b7308ad8c5e04f731c326078e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004696.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004696 +Opened: 2023-05-29 Investigator: INV-007 Severity: critical +Customer: CUST-01412 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004697.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004697.txt new file mode 100644 index 0000000000000000000000000000000000000000..36701f3c59d5df49e8e77fb0b3291a97b3db4c9a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004697.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004697 +Opened: 2023-09-08 Investigator: INV-005 Severity: high +Customer: CUST-01412 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004698.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004698.txt new file mode 100644 index 0000000000000000000000000000000000000000..8dc12bbb8645fd4ef7c3873d0f3491899d25688a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004698.txt @@ -0,0 +1 @@ +Case CASE-004698 opened 2018-08-06 re: customer CUST-01414 (delivery, OR). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-001. Suspicious activity identified consistent with structuring. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004699.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004699.txt new file mode 100644 index 0000000000000000000000000000000000000000..1bfe5c61406b2f68b812da9e648ce45ec1d5b881 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004699.txt @@ -0,0 +1 @@ +Case CASE-004699 opened 2018-12-03 re: customer CUST-01414 (delivery, OR). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004700.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004700.txt new file mode 100644 index 0000000000000000000000000000000000000000..8ec1ef1bb643e3adf042a2bcd95eb06303be792f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004700.txt @@ -0,0 +1 @@ +Case CASE-004700 opened 2019-02-18 re: customer CUST-01414 (delivery, OR). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004701.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004701.txt new file mode 100644 index 0000000000000000000000000000000000000000..210dbd358a432958b36a524cae676b6a3b6774cd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004701.txt @@ -0,0 +1 @@ +Case CASE-004701 opened 2019-04-05 re: customer CUST-01414 (delivery, OR). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004702.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004702.txt new file mode 100644 index 0000000000000000000000000000000000000000..9109c958f60ac2f9e7fcbee204afd5d3ff72e5fe --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004702.txt @@ -0,0 +1 @@ +Case CASE-004702 opened 2019-05-16 re: customer CUST-01414 (delivery, OR). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-003. Suspicious activity identified consistent with cash_threshold. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004703.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004703.txt new file mode 100644 index 0000000000000000000000000000000000000000..73632f5fcf798d72d08afe359fa6141e50cdd98a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004703.txt @@ -0,0 +1 @@ +Case CASE-004703 opened 2019-10-14 re: customer CUST-01414 (delivery, OR). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004704.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004704.txt new file mode 100644 index 0000000000000000000000000000000000000000..8e1b4e140eb104fa4c84dbb524a2f42a96a94ccb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004704.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004704 +Opened: 2021-06-03 Investigator: INV-001 Severity: critical +Customer: CUST-01414 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004705.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004705.txt new file mode 100644 index 0000000000000000000000000000000000000000..e6b7a8f13f698400cf048897152d5bfafd9d0bb8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004705.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004705 +Opened: 2021-10-06 Investigator: INV-002 Severity: high +Customer: CUST-01414 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004706.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004706.txt new file mode 100644 index 0000000000000000000000000000000000000000..3636e178ad8c67bc86f65a77354872320d566b71 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004706.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004706 +Opened: 2022-09-06 Investigator: INV-003 Severity: high +Customer: CUST-01414 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004707.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004707.txt new file mode 100644 index 0000000000000000000000000000000000000000..69540c09c2e913c12c2760c2198a366150455b45 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004707.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004707 +Opened: 2022-10-17 Investigator: INV-004 Severity: critical +Customer: CUST-01414 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004708.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004708.txt new file mode 100644 index 0000000000000000000000000000000000000000..dfdcfccff599065486caea3bf6fc9fca37e2898c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004708.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004708 +Opened: 2024-05-06 Investigator: INV-006 Severity: critical +Customer: CUST-01414 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004709.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004709.txt new file mode 100644 index 0000000000000000000000000000000000000000..eba0cf34cfa1d463fca5fcd19f1c9ba30d9ea3fb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004709.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004709 +Opened: 2024-10-08 Investigator: INV-003 Severity: high +Customer: CUST-01414 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004710.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004710.txt new file mode 100644 index 0000000000000000000000000000000000000000..a120fe49ac90ad78c5c41648e0f73846cf6ff5ec --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004710.txt @@ -0,0 +1 @@ +Case CASE-004710 opened 2018-12-13 re: customer CUST-01415 (nursery, WA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-002. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004711.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004711.txt new file mode 100644 index 0000000000000000000000000000000000000000..208426290626e23e368f323f610bb8d2f0428e37 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004711.txt @@ -0,0 +1 @@ +Case CASE-004711 opened 2019-09-02 re: customer CUST-01415 (nursery, WA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-003. Suspicious activity identified consistent with structuring. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004712.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004712.txt new file mode 100644 index 0000000000000000000000000000000000000000..8ecd1c121a11c515d2619a673c799f69e12e8c82 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004712.txt @@ -0,0 +1 @@ +Case CASE-004712 opened 2020-11-23 re: customer CUST-01415 (nursery, WA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004713.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004713.txt new file mode 100644 index 0000000000000000000000000000000000000000..236053457443d0bf3e21ac2b23378b6a4df2f9cb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004713.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004713 +Opened: 2022-02-07 Investigator: INV-003 Severity: high +Customer: CUST-01415 — nursery operating in WA. + +1. BACKGROUND +The customer is a nursery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004714.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004714.txt new file mode 100644 index 0000000000000000000000000000000000000000..f91d45b76f43486f2d666b7f9c8217bb7236acc4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004714.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004714 +Opened: 2022-04-11 Investigator: INV-002 Severity: high +Customer: CUST-01415 — nursery operating in WA. + +1. BACKGROUND +The customer is a nursery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004715.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004715.txt new file mode 100644 index 0000000000000000000000000000000000000000..49e52212313e09d432253b09ac38087f3f69c061 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004715.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004715 +Opened: 2022-08-15 Investigator: INV-007 Severity: high +Customer: CUST-01415 — nursery operating in WA. + +1. BACKGROUND +The customer is a nursery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004716.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004716.txt new file mode 100644 index 0000000000000000000000000000000000000000..600af838237804ff25542259e1bb6a83a946aff1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004716.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004716 +Opened: 2023-01-05 Investigator: INV-009 Severity: high +Customer: CUST-01415 — nursery operating in WA. + +1. BACKGROUND +The customer is a nursery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004717.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004717.txt new file mode 100644 index 0000000000000000000000000000000000000000..1cb892c6093c51044b49c2e246f3fed44f006af2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004717.txt @@ -0,0 +1 @@ +Case CASE-004717 opened 2020-03-05 re: customer CUST-01416 (nursery, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-006. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004718.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004718.txt new file mode 100644 index 0000000000000000000000000000000000000000..395e6314997cc3bccf930db1e37092b9e582bd84 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004718.txt @@ -0,0 +1 @@ +Case CASE-004718 opened 2020-07-03 re: customer CUST-01416 (nursery, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-007. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004719.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004719.txt new file mode 100644 index 0000000000000000000000000000000000000000..830fd6fca35508122ac9a950cc265d65fc7c43ff --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004719.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004719 +Opened: 2021-09-13 Investigator: INV-008 Severity: high +Customer: CUST-01416 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004720.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004720.txt new file mode 100644 index 0000000000000000000000000000000000000000..21828603a2c9c5743fd549545e19f22a19a0e9c1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004720.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004720 +Opened: 2022-09-12 Investigator: INV-009 Severity: critical +Customer: CUST-01416 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004721.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004721.txt new file mode 100644 index 0000000000000000000000000000000000000000..dbb3a7e14e2f72fc6341f3403d4c3bee7e95285d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004721.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004721 +Opened: 2023-05-22 Investigator: INV-008 Severity: high +Customer: CUST-01416 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004722.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004722.txt new file mode 100644 index 0000000000000000000000000000000000000000..78953e74e38050e031707cfcb8814a364df89284 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004722.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004722 +Opened: 2023-07-17 Investigator: INV-010 Severity: high +Customer: CUST-01416 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004723.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004723.txt new file mode 100644 index 0000000000000000000000000000000000000000..9d6ed093d6b37764964d27a81bb3df35f54fee2c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004723.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004723 +Opened: 2024-06-17 Investigator: INV-006 Severity: high +Customer: CUST-01416 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004724.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004724.txt new file mode 100644 index 0000000000000000000000000000000000000000..27e648d5cc060d6e4959e82bf83e8cdbb18d856e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004724.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004724 +Opened: 2021-07-12 Investigator: INV-001 Severity: critical +Customer: CUST-01417 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004725.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004725.txt new file mode 100644 index 0000000000000000000000000000000000000000..43e2245da417d2d5531e6063a9d0b324d29483bd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004725.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004725 +Opened: 2022-02-21 Investigator: INV-006 Severity: high +Customer: CUST-01417 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004726.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004726.txt new file mode 100644 index 0000000000000000000000000000000000000000..02d29c06b38bc4f109ecb9fe7f4c1fa7dfc5d8b3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004726.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004726 +Opened: 2022-06-03 Investigator: INV-006 Severity: critical +Customer: CUST-01417 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004727.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004727.txt new file mode 100644 index 0000000000000000000000000000000000000000..79802d76cf3eef3727e06361f3d90fb3f6b29ca0 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004727.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004727 +Opened: 2023-08-14 Investigator: INV-007 Severity: high +Customer: CUST-01417 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004728.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004728.txt new file mode 100644 index 0000000000000000000000000000000000000000..677ceeafc28469ba46e7f04af8fc740bba44b583 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004728.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004728 +Opened: 2023-10-12 Investigator: INV-006 Severity: critical +Customer: CUST-01417 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004729.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004729.txt new file mode 100644 index 0000000000000000000000000000000000000000..16266918a40204e5207875e1c7e693f445e8e43d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004729.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004729 +Opened: 2024-09-04 Investigator: INV-010 Severity: high +Customer: CUST-01418 — manufacturing operating in NV. + +1. BACKGROUND +The customer is a manufacturing licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004730.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004730.txt new file mode 100644 index 0000000000000000000000000000000000000000..f59ceacf20678d14939bf97c6d5857efbbf76a8b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004730.txt @@ -0,0 +1 @@ +Case CASE-004730 opened 2020-06-01 re: customer CUST-01420 (ancillary_service, CO). Alert type: negative_news. 1 alert(s) reviewed. Risk tier at open: low. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004731.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004731.txt new file mode 100644 index 0000000000000000000000000000000000000000..9743515894c59e59b6b9bff199dec3a27f23bddb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004731.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004731 +Opened: 2024-08-09 Investigator: INV-009 Severity: high +Customer: CUST-01423 — delivery operating in CO. + +1. BACKGROUND +The customer is a delivery licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004732.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004732.txt new file mode 100644 index 0000000000000000000000000000000000000000..0c426805d4b66354e1d834163e6f65a347187f45 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004732.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004732 +Opened: 2024-10-14 Investigator: INV-004 Severity: high +Customer: CUST-01423 — delivery operating in CO. + +1. BACKGROUND +The customer is a delivery licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004733.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004733.txt new file mode 100644 index 0000000000000000000000000000000000000000..ff4811efc2b468e3a9e43febb5dcbf930e7a1640 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004733.txt @@ -0,0 +1 @@ +Case CASE-004733 opened 2018-08-06 re: customer CUST-01424 (manufacturing, WA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004734.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004734.txt new file mode 100644 index 0000000000000000000000000000000000000000..fb1a23d7494c0923ac3da8f7a3b9e6ba9f673b70 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004734.txt @@ -0,0 +1 @@ +Case CASE-004734 opened 2019-07-03 re: customer CUST-01424 (manufacturing, WA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004735.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004735.txt new file mode 100644 index 0000000000000000000000000000000000000000..bbf560acd63d6ec092b7c00f8b7a285d58538267 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004735.txt @@ -0,0 +1 @@ +Case CASE-004735 opened 2020-06-02 re: customer CUST-01424 (manufacturing, WA). Alert type: cash_threshold. 2 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004736.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004736.txt new file mode 100644 index 0000000000000000000000000000000000000000..3a4ab0b87c2dcb127872fc63edf3a1835722db42 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004736.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004736 +Opened: 2021-09-13 Investigator: INV-003 Severity: critical +Customer: CUST-01424 — manufacturing operating in WA. + +1. BACKGROUND +The customer is a manufacturing licensed in WA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004737.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004737.txt new file mode 100644 index 0000000000000000000000000000000000000000..4542b767b8fc95cc6a3c08d3446d608219a21ad3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004737.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004737 +Opened: 2023-12-07 Investigator: INV-009 Severity: critical +Customer: CUST-01424 — manufacturing operating in WA. + +1. BACKGROUND +The customer is a manufacturing licensed in WA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004738.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004738.txt new file mode 100644 index 0000000000000000000000000000000000000000..1d40aa35503570838af54ecba99c7e5a787b0546 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004738.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004738 +Opened: 2024-09-02 Investigator: INV-009 Severity: high +Customer: CUST-01424 — manufacturing operating in WA. + +1. BACKGROUND +The customer is a manufacturing licensed in WA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004739.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004739.txt new file mode 100644 index 0000000000000000000000000000000000000000..110887e105a7d8913a154d1623b8d284c3341ebf --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004739.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004739 +Opened: 2022-08-09 Investigator: INV-006 Severity: high +Customer: CUST-01425 — event_organizer operating in CO. + +1. BACKGROUND +The customer is a event_organizer licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004740.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004740.txt new file mode 100644 index 0000000000000000000000000000000000000000..e295c67f5f2e4f15202e8ed8c5fa95b41ddab487 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004740.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004740 +Opened: 2022-09-27 Investigator: INV-008 Severity: high +Customer: CUST-01425 — event_organizer operating in CO. + +1. BACKGROUND +The customer is a event_organizer licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type geo_anomaly generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004741.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004741.txt new file mode 100644 index 0000000000000000000000000000000000000000..ccabb819435b5735c46dc2f05407cdffbbe0907d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004741.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004741 +Opened: 2023-01-20 Investigator: INV-009 Severity: high +Customer: CUST-01425 — event_organizer operating in CO. + +1. BACKGROUND +The customer is a event_organizer licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004742.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004742.txt new file mode 100644 index 0000000000000000000000000000000000000000..e624e1df96364cc1b26c3000f98b6544cefca98c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004742.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004742 +Opened: 2023-08-10 Investigator: INV-001 Severity: high +Customer: CUST-01425 — event_organizer operating in CO. + +1. BACKGROUND +The customer is a event_organizer licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004743.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004743.txt new file mode 100644 index 0000000000000000000000000000000000000000..9fd03ae90ce20486d2c09f7813511c0365922369 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004743.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004743 +Opened: 2024-01-19 Investigator: INV-006 Severity: moderate +Customer: CUST-01425 — event_organizer operating in CO. + +1. BACKGROUND +The customer is a event_organizer licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004744.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004744.txt new file mode 100644 index 0000000000000000000000000000000000000000..831cf088886b4c6483c3147232740fde4b98c80a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004744.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004744 +Opened: 2023-01-30 Investigator: INV-009 Severity: high +Customer: CUST-01426 — professional_service operating in CA. + +1. BACKGROUND +The customer is a professional_service licensed in CA. At case open the point-in-time risk tier was low, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cannabis_wire_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004745.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004745.txt new file mode 100644 index 0000000000000000000000000000000000000000..a9f74f14eb9233b3e81ba143f0db78f48cc3c10c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004745.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004745 +Opened: 2022-09-12 Investigator: INV-007 Severity: high +Customer: CUST-01427 — transport operating in CA. + +1. BACKGROUND +The customer is a transport licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004746.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004746.txt new file mode 100644 index 0000000000000000000000000000000000000000..f2142441734f3c0c1cd30111926cfa9e8d69b4c0 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004746.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004746 +Opened: 2023-06-13 Investigator: INV-008 Severity: critical +Customer: CUST-01427 — transport operating in CA. + +1. BACKGROUND +The customer is a transport licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004747.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004747.txt new file mode 100644 index 0000000000000000000000000000000000000000..b09948a2d491b91c89454a0286ef1b5422add765 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004747.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004747 +Opened: 2023-11-09 Investigator: INV-008 Severity: high +Customer: CUST-01427 — transport operating in CA. + +1. BACKGROUND +The customer is a transport licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004748.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004748.txt new file mode 100644 index 0000000000000000000000000000000000000000..2cedd44f19835306d0377c886b77cff03c3ab131 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004748.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004748 +Opened: 2023-04-10 Investigator: INV-007 Severity: high +Customer: CUST-01428 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004749.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004749.txt new file mode 100644 index 0000000000000000000000000000000000000000..0307e0c7e8fe6a5f720151c546aaf3630515c98f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004749.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004749 +Opened: 2023-07-03 Investigator: INV-010 Severity: high +Customer: CUST-01428 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004750.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004750.txt new file mode 100644 index 0000000000000000000000000000000000000000..b64199a9f4313bdba30e78d0f25f4ddc17bd0f38 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004750.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004750 +Opened: 2024-06-24 Investigator: INV-004 Severity: high +Customer: CUST-01428 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004751.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004751.txt new file mode 100644 index 0000000000000000000000000000000000000000..1158dee68cb4c6dbcf9bbd598315611df1605df4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004751.txt @@ -0,0 +1 @@ +Case CASE-004751 opened 2019-11-04 re: customer CUST-01429 (microbusiness, CO). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004752.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004752.txt new file mode 100644 index 0000000000000000000000000000000000000000..05f5242017d35baa269e7321b93d6eef850e9a2e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004752.txt @@ -0,0 +1 @@ +Case CASE-004752 opened 2020-04-09 re: customer CUST-01429 (microbusiness, CO). Alert type: cannabis_wire_monitor. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004753.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004753.txt new file mode 100644 index 0000000000000000000000000000000000000000..d6f973a6c45fbfffce4fbff902f27b40e9507447 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004753.txt @@ -0,0 +1 @@ +Case CASE-004753 opened 2020-09-11 re: customer CUST-01429 (microbusiness, CO). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-007. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004754.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004754.txt new file mode 100644 index 0000000000000000000000000000000000000000..920668400bb19290ca23f2716e67f67bd43dccf4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004754.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004754 +Opened: 2022-01-14 Investigator: INV-006 Severity: high +Customer: CUST-01429 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004755.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004755.txt new file mode 100644 index 0000000000000000000000000000000000000000..5d43eba38c3ad7c9ce8798176884021f7097aa92 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004755.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004755 +Opened: 2022-10-10 Investigator: INV-004 Severity: high +Customer: CUST-01429 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004756.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004756.txt new file mode 100644 index 0000000000000000000000000000000000000000..b6a240f1633c8252eebed1cf6b0f08130874d970 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004756.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004756 +Opened: 2023-03-03 Investigator: INV-008 Severity: high +Customer: CUST-01429 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004757.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004757.txt new file mode 100644 index 0000000000000000000000000000000000000000..11ae63907fc2dac352669cc206bc21c9d43719cb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004757.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004757 +Opened: 2023-04-05 Investigator: INV-001 Severity: high +Customer: CUST-01429 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004758.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004758.txt new file mode 100644 index 0000000000000000000000000000000000000000..8f327e5997f05ed6d15ed3054359ecadacdadc3e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004758.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004758 +Opened: 2023-09-20 Investigator: INV-008 Severity: high +Customer: CUST-01429 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004759.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004759.txt new file mode 100644 index 0000000000000000000000000000000000000000..720201c654645581153d66e60d10b094581cec1f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004759.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004759 +Opened: 2023-11-07 Investigator: INV-006 Severity: high +Customer: CUST-01429 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004760.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004760.txt new file mode 100644 index 0000000000000000000000000000000000000000..7d6eace9edf131a24aaebed354cd80a9215399ba --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004760.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004760 +Opened: 2024-09-11 Investigator: INV-003 Severity: moderate +Customer: CUST-01429 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004761.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004761.txt new file mode 100644 index 0000000000000000000000000000000000000000..f7d06be2fe10b1cceba47ee912f0c167d48e7111 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004761.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004761 +Opened: 2023-05-16 Investigator: INV-003 Severity: high +Customer: CUST-01430 — ancillary_service operating in OR. + +1. BACKGROUND +The customer is a ancillary_service licensed in OR. At case open the point-in-time risk tier was low, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004762.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004762.txt new file mode 100644 index 0000000000000000000000000000000000000000..14633ab87a6ddc8ca40d1af34d42feb0ad625115 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004762.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004762 +Opened: 2022-05-09 Investigator: INV-009 Severity: high +Customer: CUST-01431 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004763.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004763.txt new file mode 100644 index 0000000000000000000000000000000000000000..eaef47d12d973357518072b9243a27780aba937d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004763.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004763 +Opened: 2024-02-05 Investigator: INV-010 Severity: high +Customer: CUST-01431 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004764.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004764.txt new file mode 100644 index 0000000000000000000000000000000000000000..8e4d0793593cc412c02c98371562452a37e98eb1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004764.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004764 +Opened: 2024-05-06 Investigator: INV-006 Severity: critical +Customer: CUST-01431 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004765.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004765.txt new file mode 100644 index 0000000000000000000000000000000000000000..eb5afc4a851c6471c8fbc08f690289054a39663f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004765.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004765 +Opened: 2024-07-03 Investigator: INV-006 Severity: high +Customer: CUST-01432 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004766.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004766.txt new file mode 100644 index 0000000000000000000000000000000000000000..32436e9a76fe7bee8b2f473237aecaecd6af0cdd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004766.txt @@ -0,0 +1 @@ +Case CASE-004766 opened 2019-01-18 re: customer CUST-01434 (dispensary, NV). Alert type: pep_monitor. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-002. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004767.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004767.txt new file mode 100644 index 0000000000000000000000000000000000000000..528629957532ca6c2e16ae73b6625bd2906bcf55 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004767.txt @@ -0,0 +1 @@ +Case CASE-004767 opened 2020-06-29 re: customer CUST-01434 (dispensary, NV). Alert type: velocity. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-006. Suspicious activity identified consistent with velocity. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004768.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004768.txt new file mode 100644 index 0000000000000000000000000000000000000000..dc2980abf7a1fcc14e9237afccc027b4874fe65e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004768.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004768 +Opened: 2022-01-10 Investigator: INV-008 Severity: high +Customer: CUST-01434 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004769.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004769.txt new file mode 100644 index 0000000000000000000000000000000000000000..db1eac042a93d8cb205cdd0bfe973e2031f3aaa4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004769.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004769 +Opened: 2022-05-19 Investigator: INV-008 Severity: high +Customer: CUST-01434 — dispensary operating in NV. + +1. BACKGROUND +The customer is a dispensary licensed in NV. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004770.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004770.txt new file mode 100644 index 0000000000000000000000000000000000000000..daf4f47f7af4765ae8df5af42172c2d43343cb7b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004770.txt @@ -0,0 +1 @@ +Case CASE-004770 opened 2019-06-03 re: customer CUST-01435 (manufacturing, OR). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004771.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004771.txt new file mode 100644 index 0000000000000000000000000000000000000000..d9f60377293b4837c46918fcb8c9b684b16cc0e7 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004771.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004771 +Opened: 2021-01-28 Investigator: INV-002 Severity: high +Customer: CUST-01435 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004772.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004772.txt new file mode 100644 index 0000000000000000000000000000000000000000..8459ff0623378eb6d1cfe75640c8e56db5aefe02 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004772.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004772 +Opened: 2021-09-13 Investigator: INV-005 Severity: high +Customer: CUST-01435 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004773.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004773.txt new file mode 100644 index 0000000000000000000000000000000000000000..0f1904da2c62513d6c59ba206cebf763f3949ac8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004773.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004773 +Opened: 2021-12-06 Investigator: INV-004 Severity: high +Customer: CUST-01435 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004774.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004774.txt new file mode 100644 index 0000000000000000000000000000000000000000..3a091fa3451f2287f26593f6cd8966b56484a6c7 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004774.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004774 +Opened: 2024-09-09 Investigator: INV-009 Severity: high +Customer: CUST-01435 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004775.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004775.txt new file mode 100644 index 0000000000000000000000000000000000000000..e7341618b11a7f7fd1d217a453cbdd7cca5e2062 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004775.txt @@ -0,0 +1 @@ +Case CASE-004775 opened 2020-02-03 re: customer CUST-01436 (dispensary, WA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004776.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004776.txt new file mode 100644 index 0000000000000000000000000000000000000000..3e13c67d1dbc3e5f1918e8fb7f6fc286a1be537d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004776.txt @@ -0,0 +1 @@ +Case CASE-004776 opened 2020-06-08 re: customer CUST-01436 (dispensary, WA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004777.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004777.txt new file mode 100644 index 0000000000000000000000000000000000000000..46bdee790d8558e947c62d3e45dc5f98c9a6191a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004777.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004777 +Opened: 2023-11-06 Investigator: INV-001 Severity: high +Customer: CUST-01437 — event_organizer operating in NV. + +1. BACKGROUND +The customer is a event_organizer licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004778.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004778.txt new file mode 100644 index 0000000000000000000000000000000000000000..c1d74c0279eca26b3e72fc56e9c83204201efef8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004778.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004778 +Opened: 2021-07-05 Investigator: INV-005 Severity: high +Customer: CUST-01439 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004779.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004779.txt new file mode 100644 index 0000000000000000000000000000000000000000..ce47bb00bbbe0f5ecfbd1a95045c222eb947f5a6 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004779.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004779 +Opened: 2024-07-02 Investigator: INV-009 Severity: high +Customer: CUST-01439 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004780.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004780.txt new file mode 100644 index 0000000000000000000000000000000000000000..3d14b7f933778892a6c1e6d94e93e62a0885bd52 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004780.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004780 +Opened: 2022-06-13 Investigator: INV-007 Severity: high +Customer: CUST-01440 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004781.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004781.txt new file mode 100644 index 0000000000000000000000000000000000000000..12ce9c4c36624df48def28d5d6f2fd251d216a17 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004781.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004781 +Opened: 2022-10-31 Investigator: INV-003 Severity: high +Customer: CUST-01440 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004782.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004782.txt new file mode 100644 index 0000000000000000000000000000000000000000..02b33deefd392aaf5b8125b004309359643f3dcb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004782.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004782 +Opened: 2022-12-12 Investigator: INV-004 Severity: high +Customer: CUST-01440 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004783.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004783.txt new file mode 100644 index 0000000000000000000000000000000000000000..7dc8f3b6c0037e9905ef9c81e5144cc0e97185f8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004783.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004783 +Opened: 2024-08-16 Investigator: INV-003 Severity: high +Customer: CUST-01440 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004784.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004784.txt new file mode 100644 index 0000000000000000000000000000000000000000..1979e7bd4174ddec12440f1ca623e7e9767ceecb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004784.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004784 +Opened: 2024-11-13 Investigator: INV-007 Severity: high +Customer: CUST-01440 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004785.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004785.txt new file mode 100644 index 0000000000000000000000000000000000000000..a1229f98db1f80d6dd616b4814f5c267b793bef3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004785.txt @@ -0,0 +1 @@ +Case CASE-004785 opened 2020-03-16 re: customer CUST-01441 (microbusiness, MI). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-006. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004786.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004786.txt new file mode 100644 index 0000000000000000000000000000000000000000..b7dcd05ac5854c4d091ee1340becba524f381420 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004786.txt @@ -0,0 +1 @@ +Case CASE-004786 opened 2020-12-21 re: customer CUST-01441 (microbusiness, MI). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-005. Suspicious activity identified consistent with structuring. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004787.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004787.txt new file mode 100644 index 0000000000000000000000000000000000000000..3ca3497f06fed5daab251ffc15b02fbddc32f026 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004787.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004787 +Opened: 2021-10-11 Investigator: INV-006 Severity: critical +Customer: CUST-01441 — microbusiness operating in MI. + +1. BACKGROUND +The customer is a microbusiness licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004788.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004788.txt new file mode 100644 index 0000000000000000000000000000000000000000..e2c7df9d18f046619566d0854fe74164d717dee8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004788.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004788 +Opened: 2021-12-10 Investigator: INV-001 Severity: high +Customer: CUST-01442 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004789.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004789.txt new file mode 100644 index 0000000000000000000000000000000000000000..2cc412e2cc286dea5bbe649c347c4898f33c2259 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004789.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004789 +Opened: 2022-01-11 Investigator: INV-006 Severity: high +Customer: CUST-01442 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004790.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004790.txt new file mode 100644 index 0000000000000000000000000000000000000000..0d82252f63e7f98828bae9d162458c67ec8dee1d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004790.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004790 +Opened: 2022-08-08 Investigator: INV-008 Severity: high +Customer: CUST-01442 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cannabis_wire_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004791.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004791.txt new file mode 100644 index 0000000000000000000000000000000000000000..da341e36041edb30f606ccc556af5fcd50794e1b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004791.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004791 +Opened: 2024-09-06 Investigator: INV-001 Severity: critical +Customer: CUST-01442 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cannabis_wire_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004792.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004792.txt new file mode 100644 index 0000000000000000000000000000000000000000..e026b1857d612ce5aac951961558f60f72f768cd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004792.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004792 +Opened: 2023-12-14 Investigator: INV-003 Severity: high +Customer: CUST-01443 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004793.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004793.txt new file mode 100644 index 0000000000000000000000000000000000000000..61410feb81782fa52f1aaa5d53838da9bcc53676 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004793.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004793 +Opened: 2024-06-24 Investigator: INV-001 Severity: high +Customer: CUST-01443 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004794.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004794.txt new file mode 100644 index 0000000000000000000000000000000000000000..bc1224ce29d3e2a4f9af8895516c6f290cbf11e8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004794.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004794 +Opened: 2024-10-30 Investigator: INV-001 Severity: high +Customer: CUST-01443 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004795.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004795.txt new file mode 100644 index 0000000000000000000000000000000000000000..07e7b05085169627c71e83aebb58b4ac48ee71ee --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004795.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004795 +Opened: 2024-11-26 Investigator: INV-008 Severity: high +Customer: CUST-01443 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004796.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004796.txt new file mode 100644 index 0000000000000000000000000000000000000000..fa690e7f17349aea6a4320fe8523add3f6194e09 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004796.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004796 +Opened: 2023-07-25 Investigator: INV-007 Severity: high +Customer: CUST-01444 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type wire_to_cash generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004797.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004797.txt new file mode 100644 index 0000000000000000000000000000000000000000..861add473c105781fe6ecc335a52832387d80e1d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004797.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004797 +Opened: 2024-03-18 Investigator: INV-010 Severity: high +Customer: CUST-01444 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004798.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004798.txt new file mode 100644 index 0000000000000000000000000000000000000000..b7c712321357fe0b48011c4dca3060e2bd5ca1b3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004798.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004798 +Opened: 2024-07-09 Investigator: INV-006 Severity: critical +Customer: CUST-01444 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004799.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004799.txt new file mode 100644 index 0000000000000000000000000000000000000000..2abbe6ab58dc0ddf29e33649c0b61c3d3cba92ce --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004799.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004799 +Opened: 2024-10-03 Investigator: INV-008 Severity: critical +Customer: CUST-01444 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004800.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004800.txt new file mode 100644 index 0000000000000000000000000000000000000000..bba6de8ab50762fe9dc12bc6ea27961a8189b3e0 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-04/CASE-004800.txt @@ -0,0 +1 @@ +Case CASE-004800 opened 2020-06-08 re: customer CUST-01445 (cultivation, MI). Alert type: high_risk_jurisdiction. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004801.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004801.txt new file mode 100644 index 0000000000000000000000000000000000000000..c44caea47f7c508492bd76536a2aa0f3ce8df55e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004801.txt @@ -0,0 +1 @@ +Case CASE-004801 opened 2020-08-10 re: customer CUST-01445 (cultivation, MI). Alert type: nighttime_activity. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-007. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004802.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004802.txt new file mode 100644 index 0000000000000000000000000000000000000000..3186484e7c6cf5c3c9782b9021bacbc7f565b5f6 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004802.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004802 +Opened: 2021-02-05 Investigator: INV-005 Severity: high +Customer: CUST-01445 — cultivation operating in MI. + +1. BACKGROUND +The customer is a cultivation licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004803.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004803.txt new file mode 100644 index 0000000000000000000000000000000000000000..55c216cfab2e6b7b9a474242ad32de9faae9fa00 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004803.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004803 +Opened: 2021-03-05 Investigator: INV-004 Severity: critical +Customer: CUST-01445 — cultivation operating in MI. + +1. BACKGROUND +The customer is a cultivation licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004804.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004804.txt new file mode 100644 index 0000000000000000000000000000000000000000..64a9f65cab08e16f859047ebf2bb52f546380595 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004804.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004804 +Opened: 2021-07-19 Investigator: INV-006 Severity: high +Customer: CUST-01445 — cultivation operating in MI. + +1. BACKGROUND +The customer is a cultivation licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004805.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004805.txt new file mode 100644 index 0000000000000000000000000000000000000000..acbdca792ceba0ab848d89000c719e70dbc31818 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004805.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004805 +Opened: 2022-01-03 Investigator: INV-004 Severity: high +Customer: CUST-01445 — cultivation operating in MI. + +1. BACKGROUND +The customer is a cultivation licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004806.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004806.txt new file mode 100644 index 0000000000000000000000000000000000000000..be2d6c182a9e2b38da038d27afa50dc87928a059 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004806.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004806 +Opened: 2021-04-02 Investigator: INV-003 Severity: high +Customer: CUST-01446 — distribution operating in WA. + +1. BACKGROUND +The customer is a distribution licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004807.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004807.txt new file mode 100644 index 0000000000000000000000000000000000000000..b8c38994e63986095aa18f8da5f69dde633297f5 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004807.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004807 +Opened: 2021-08-06 Investigator: INV-002 Severity: high +Customer: CUST-01446 — distribution operating in WA. + +1. BACKGROUND +The customer is a distribution licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004808.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004808.txt new file mode 100644 index 0000000000000000000000000000000000000000..79ab3d419f39c0c76a166f0f5e897f62e5e5d15f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004808.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004808 +Opened: 2023-03-13 Investigator: INV-010 Severity: high +Customer: CUST-01446 — distribution operating in WA. + +1. BACKGROUND +The customer is a distribution licensed in WA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004809.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004809.txt new file mode 100644 index 0000000000000000000000000000000000000000..1a82901244e04f83b0f2fabb13df15fce09a88b5 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004809.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004809 +Opened: 2024-01-24 Investigator: INV-010 Severity: high +Customer: CUST-01446 — distribution operating in WA. + +1. BACKGROUND +The customer is a distribution licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004810.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004810.txt new file mode 100644 index 0000000000000000000000000000000000000000..e1fc98b270a7defa2b7f83dab220f07b7127c8fd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004810.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004810 +Opened: 2021-06-02 Investigator: INV-002 Severity: critical +Customer: CUST-01447 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004811.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004811.txt new file mode 100644 index 0000000000000000000000000000000000000000..678afef03fe20feefd35561a7931815ea5143a5e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004811.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004811 +Opened: 2021-11-12 Investigator: INV-001 Severity: critical +Customer: CUST-01447 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004812.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004812.txt new file mode 100644 index 0000000000000000000000000000000000000000..6b8441d0b7c6933181b3dc6d7fb8c16f4dec6342 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004812.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004812 +Opened: 2022-04-11 Investigator: INV-008 Severity: high +Customer: CUST-01447 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004813.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004813.txt new file mode 100644 index 0000000000000000000000000000000000000000..c396cc829ed97fa088905cccd72214e1e3e3f041 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004813.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004813 +Opened: 2023-11-06 Investigator: INV-007 Severity: high +Customer: CUST-01447 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004814.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004814.txt new file mode 100644 index 0000000000000000000000000000000000000000..e299ede220cb41aa0e3490b3692dce951408dfeb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004814.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004814 +Opened: 2021-04-19 Investigator: INV-008 Severity: high +Customer: CUST-01448 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004815.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004815.txt new file mode 100644 index 0000000000000000000000000000000000000000..9d7404edc514da53fe3dfe98ea6082c76f1f2365 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004815.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004815 +Opened: 2021-12-24 Investigator: INV-004 Severity: high +Customer: CUST-01448 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004816.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004816.txt new file mode 100644 index 0000000000000000000000000000000000000000..aaf8ec470d05f46d72ac70c02d45254a817c0767 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004816.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004816 +Opened: 2022-03-15 Investigator: INV-003 Severity: high +Customer: CUST-01448 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004817.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004817.txt new file mode 100644 index 0000000000000000000000000000000000000000..5b990f630a2e67019e54127b458d4176896f82fe --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004817.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004817 +Opened: 2022-08-29 Investigator: INV-006 Severity: high +Customer: CUST-01448 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004818.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004818.txt new file mode 100644 index 0000000000000000000000000000000000000000..9cd9eaf1268a6f8e9410abdf510c2a652685386b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004818.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004818 +Opened: 2022-11-22 Investigator: INV-006 Severity: high +Customer: CUST-01448 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004819.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004819.txt new file mode 100644 index 0000000000000000000000000000000000000000..60b99604b77bbebb4f43cfbe070716ab9992347d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004819.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004819 +Opened: 2022-12-27 Investigator: INV-001 Severity: high +Customer: CUST-01448 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004820.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004820.txt new file mode 100644 index 0000000000000000000000000000000000000000..73d5521f7db00a163b78a7caf1dbe7006ea52936 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004820.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004820 +Opened: 2023-03-24 Investigator: INV-006 Severity: high +Customer: CUST-01448 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004821.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004821.txt new file mode 100644 index 0000000000000000000000000000000000000000..33550784f0485bb071a8172761e8b5d6f8869bfd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004821.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004821 +Opened: 2023-08-14 Investigator: INV-005 Severity: high +Customer: CUST-01448 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004822.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004822.txt new file mode 100644 index 0000000000000000000000000000000000000000..7ffac68c82a6327f6a97ef696f6c10a6a07c90ec --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004822.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004822 +Opened: 2024-03-25 Investigator: INV-007 Severity: critical +Customer: CUST-01448 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004823.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004823.txt new file mode 100644 index 0000000000000000000000000000000000000000..31e12fa7fb95747a9355dd39663e10f0dac19aae --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004823.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004823 +Opened: 2024-07-30 Investigator: INV-008 Severity: high +Customer: CUST-01448 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type wire_to_cash generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004824.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004824.txt new file mode 100644 index 0000000000000000000000000000000000000000..2988773146138b591ec8d0851e2dcf07ded983e2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004824.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004824 +Opened: 2022-06-07 Investigator: INV-005 Severity: high +Customer: CUST-01452 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004825.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004825.txt new file mode 100644 index 0000000000000000000000000000000000000000..4d99eebd36226e8de0bd26b92ad9fae53acdec47 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004825.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004825 +Opened: 2023-04-05 Investigator: INV-009 Severity: high +Customer: CUST-01452 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004826.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004826.txt new file mode 100644 index 0000000000000000000000000000000000000000..f207d87e0bcd6f35323f89ffa2810d1441111ee4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004826.txt @@ -0,0 +1 @@ +Case CASE-004826 opened 2019-12-09 re: customer CUST-01453 (cultivation, CO). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004827.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004827.txt new file mode 100644 index 0000000000000000000000000000000000000000..5e29673cb412ac3e5e6ec5cbeff230198ccd707b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004827.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004827 +Opened: 2022-01-04 Investigator: INV-005 Severity: high +Customer: CUST-01453 — cultivation operating in CO. + +1. BACKGROUND +The customer is a cultivation licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004828.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004828.txt new file mode 100644 index 0000000000000000000000000000000000000000..e3a9e33d9161a18e169b64bf1edc6a9664d0f5e7 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004828.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004828 +Opened: 2022-05-02 Investigator: INV-006 Severity: high +Customer: CUST-01453 — cultivation operating in CO. + +1. BACKGROUND +The customer is a cultivation licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004829.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004829.txt new file mode 100644 index 0000000000000000000000000000000000000000..b4e6fdeee1cb92e19a11d95b0641eb608ce2f512 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004829.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004829 +Opened: 2023-04-18 Investigator: INV-007 Severity: high +Customer: CUST-01453 — cultivation operating in CO. + +1. BACKGROUND +The customer is a cultivation licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004830.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004830.txt new file mode 100644 index 0000000000000000000000000000000000000000..d6a08dd2e746a923a4dee880a62bb3dca874dbb2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004830.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004830 +Opened: 2023-08-09 Investigator: INV-006 Severity: critical +Customer: CUST-01453 — cultivation operating in CO. + +1. BACKGROUND +The customer is a cultivation licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004831.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004831.txt new file mode 100644 index 0000000000000000000000000000000000000000..fe944a6d5e3f8a6d480b924c595842487bdf7625 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004831.txt @@ -0,0 +1 @@ +Case CASE-004831 opened 2020-06-09 re: customer CUST-01454 (distribution, OR). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004832.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004832.txt new file mode 100644 index 0000000000000000000000000000000000000000..38f21ec081998cb47a25cc1d30573e6d83b6e1a8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004832.txt @@ -0,0 +1 @@ +Case CASE-004832 opened 2020-09-07 re: customer CUST-01454 (distribution, OR). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004833.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004833.txt new file mode 100644 index 0000000000000000000000000000000000000000..b3d11dfe021c131da66d69d5389fc7b149acf2e9 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004833.txt @@ -0,0 +1 @@ +Case CASE-004833 opened 2020-11-09 re: customer CUST-01454 (distribution, OR). Alert type: velocity. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-003. Suspicious activity identified consistent with velocity. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004834.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004834.txt new file mode 100644 index 0000000000000000000000000000000000000000..30eff283be6145021133abc125196fb2a6a0e24e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004834.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004834 +Opened: 2021-10-25 Investigator: INV-001 Severity: critical +Customer: CUST-01454 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004835.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004835.txt new file mode 100644 index 0000000000000000000000000000000000000000..b3747319926467a6723343b843341b6d75205884 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004835.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004835 +Opened: 2022-08-08 Investigator: INV-004 Severity: high +Customer: CUST-01454 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004836.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004836.txt new file mode 100644 index 0000000000000000000000000000000000000000..9d661b146869c6847a41310db6c4f81ce1d95155 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004836.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004836 +Opened: 2023-02-01 Investigator: INV-004 Severity: high +Customer: CUST-01454 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004837.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004837.txt new file mode 100644 index 0000000000000000000000000000000000000000..d2305258ab578149604c99d53c6d666489cc8672 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004837.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004837 +Opened: 2023-11-07 Investigator: INV-003 Severity: high +Customer: CUST-01454 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004838.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004838.txt new file mode 100644 index 0000000000000000000000000000000000000000..637194225473afe893e062df6dd61021f0ba0c3a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004838.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004838 +Opened: 2023-12-05 Investigator: INV-004 Severity: high +Customer: CUST-01454 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004839.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004839.txt new file mode 100644 index 0000000000000000000000000000000000000000..b783808f507ea5297fb1dd934eaf1a6e72fec68c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004839.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004839 +Opened: 2024-02-08 Investigator: INV-004 Severity: high +Customer: CUST-01454 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004840.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004840.txt new file mode 100644 index 0000000000000000000000000000000000000000..cd60073255b0a880c9acbbf650bd2e73089a591d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004840.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004840 +Opened: 2024-06-12 Investigator: INV-001 Severity: high +Customer: CUST-01454 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004841.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004841.txt new file mode 100644 index 0000000000000000000000000000000000000000..4a216dcb04e06f43a528b376b4499e2f2531ea3a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004841.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004841 +Opened: 2024-09-05 Investigator: INV-001 Severity: high +Customer: CUST-01454 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004842.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004842.txt new file mode 100644 index 0000000000000000000000000000000000000000..c998f1f84cb64a85a708fdcfd8a232ac851db006 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004842.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004842 +Opened: 2024-11-11 Investigator: INV-009 Severity: high +Customer: CUST-01454 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004843.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004843.txt new file mode 100644 index 0000000000000000000000000000000000000000..d0b82d2c0c73fe3ae86723f8f197381481454f83 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004843.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004843 +Opened: 2023-06-02 Investigator: INV-008 Severity: high +Customer: CUST-01455 — microbusiness operating in MI. + +1. BACKGROUND +The customer is a microbusiness licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004844.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004844.txt new file mode 100644 index 0000000000000000000000000000000000000000..f6bd010f67201c632a2a89234523de2d734d27f2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004844.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004844 +Opened: 2023-09-04 Investigator: INV-005 Severity: critical +Customer: CUST-01455 — microbusiness operating in MI. + +1. BACKGROUND +The customer is a microbusiness licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004845.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004845.txt new file mode 100644 index 0000000000000000000000000000000000000000..7051a00fb65ea410a20e76b527d0a2fea205da0e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004845.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004845 +Opened: 2022-01-17 Investigator: INV-002 Severity: high +Customer: CUST-01456 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004846.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004846.txt new file mode 100644 index 0000000000000000000000000000000000000000..849b609342844a5687cb387420d4f8dc5a23e3a1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004846.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004846 +Opened: 2023-05-15 Investigator: INV-005 Severity: high +Customer: CUST-01456 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004847.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004847.txt new file mode 100644 index 0000000000000000000000000000000000000000..19a3126f5e01fc74382f4fb50167b1aa3233113b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004847.txt @@ -0,0 +1 @@ +Case CASE-004847 opened 2020-03-03 re: customer CUST-01457 (cultivation, OR). Alert type: structuring. 2 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-006. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004848.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004848.txt new file mode 100644 index 0000000000000000000000000000000000000000..e85d4b558a02fdfe3e05f923a6e75ff0389d71eb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004848.txt @@ -0,0 +1 @@ +Case CASE-004848 opened 2020-06-05 re: customer CUST-01457 (cultivation, OR). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-006. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004849.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004849.txt new file mode 100644 index 0000000000000000000000000000000000000000..fe1f1eb7a8acb5162d664791e28906d9337cb7d8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004849.txt @@ -0,0 +1 @@ +Case CASE-004849 opened 2020-12-16 re: customer CUST-01457 (cultivation, OR). Alert type: pep_monitor. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004850.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004850.txt new file mode 100644 index 0000000000000000000000000000000000000000..c3c371045442382182652b917748253d9aa19a94 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004850.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004850 +Opened: 2021-11-03 Investigator: INV-006 Severity: high +Customer: CUST-01457 — cultivation operating in OR. + +1. BACKGROUND +The customer is a cultivation licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004851.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004851.txt new file mode 100644 index 0000000000000000000000000000000000000000..560fb44fbc991141bc7911cd91df2994981b679d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004851.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004851 +Opened: 2022-11-03 Investigator: INV-008 Severity: high +Customer: CUST-01457 — cultivation operating in OR. + +1. BACKGROUND +The customer is a cultivation licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004852.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004852.txt new file mode 100644 index 0000000000000000000000000000000000000000..8e99a347025b01121a0033bf8a0cb33456882df8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004852.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004852 +Opened: 2023-01-05 Investigator: INV-009 Severity: high +Customer: CUST-01457 — cultivation operating in OR. + +1. BACKGROUND +The customer is a cultivation licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004853.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004853.txt new file mode 100644 index 0000000000000000000000000000000000000000..b76cfb150fbafba3566b96874ec1ada7aabe1e31 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004853.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004853 +Opened: 2023-03-06 Investigator: INV-006 Severity: high +Customer: CUST-01457 — cultivation operating in OR. + +1. BACKGROUND +The customer is a cultivation licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004854.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004854.txt new file mode 100644 index 0000000000000000000000000000000000000000..41ca6c8567c8cb2ce223a6c0012f32bcc36671f6 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004854.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004854 +Opened: 2024-05-20 Investigator: INV-009 Severity: high +Customer: CUST-01458 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004855.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004855.txt new file mode 100644 index 0000000000000000000000000000000000000000..3782dfeb7796a34a087e0cd7e5a1b42299980ac6 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004855.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004855 +Opened: 2024-02-12 Investigator: INV-010 Severity: high +Customer: CUST-01459 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004856.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004856.txt new file mode 100644 index 0000000000000000000000000000000000000000..81198820e2531bab5ce5c5b234b41d42a0b2088d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004856.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004856 +Opened: 2024-10-08 Investigator: INV-009 Severity: high +Customer: CUST-01460 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type wire_to_cash generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004857.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004857.txt new file mode 100644 index 0000000000000000000000000000000000000000..c7ff11c63310e4579a9e1cafeee386c765944247 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004857.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004857 +Opened: 2021-08-09 Investigator: INV-001 Severity: high +Customer: CUST-01461 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004858.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004858.txt new file mode 100644 index 0000000000000000000000000000000000000000..448c68d41cd4ede5e747c51e12a4d73729f7b039 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004858.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004858 +Opened: 2023-06-05 Investigator: INV-005 Severity: high +Customer: CUST-01461 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cannabis_wire_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004859.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004859.txt new file mode 100644 index 0000000000000000000000000000000000000000..3e2a8faa95167be32252c8f6835f91cf55b62f5f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004859.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004859 +Opened: 2024-08-05 Investigator: INV-010 Severity: high +Customer: CUST-01461 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004860.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004860.txt new file mode 100644 index 0000000000000000000000000000000000000000..f24d99c226a0003bf67be9e1da26643be20f62a6 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004860.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004860 +Opened: 2022-08-30 Investigator: INV-007 Severity: high +Customer: CUST-01462 — testing_lab operating in CO. + +1. BACKGROUND +The customer is a testing_lab licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type negative_news generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004861.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004861.txt new file mode 100644 index 0000000000000000000000000000000000000000..f71e1922385fd3007bc30d9f39b776f30ac4d96a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004861.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004861 +Opened: 2022-02-07 Investigator: INV-004 Severity: high +Customer: CUST-01463 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004862.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004862.txt new file mode 100644 index 0000000000000000000000000000000000000000..bbd00fb75a6e794eee5b5a037665d82925841770 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004862.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004862 +Opened: 2022-11-02 Investigator: INV-004 Severity: high +Customer: CUST-01463 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004863.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004863.txt new file mode 100644 index 0000000000000000000000000000000000000000..bdb3fc5c938f33b1172bea38db457118fa5e87bf --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004863.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004863 +Opened: 2024-01-09 Investigator: INV-010 Severity: high +Customer: CUST-01464 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004864.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004864.txt new file mode 100644 index 0000000000000000000000000000000000000000..fdfe5f7df5dec327f7bd02bc4dea5b01e7db4dc8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004864.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004864 +Opened: 2024-03-04 Investigator: INV-001 Severity: high +Customer: CUST-01464 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004865.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004865.txt new file mode 100644 index 0000000000000000000000000000000000000000..01916ca2ef7381e716b3a3aa5bf14fd61a27549e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004865.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004865 +Opened: 2024-11-04 Investigator: INV-004 Severity: critical +Customer: CUST-01464 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004866.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004866.txt new file mode 100644 index 0000000000000000000000000000000000000000..ca03a57b46bc6994ac10d7b2b480ae84ff1d991a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004866.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004866 +Opened: 2021-12-24 Investigator: INV-005 Severity: critical +Customer: CUST-01465 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004867.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004867.txt new file mode 100644 index 0000000000000000000000000000000000000000..004a02a90d29b6d8475fa159096374f6398b3648 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004867.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004867 +Opened: 2022-06-07 Investigator: INV-006 Severity: high +Customer: CUST-01465 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004868.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004868.txt new file mode 100644 index 0000000000000000000000000000000000000000..b417c9082ea826aae9315df23da16088aa068e9a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004868.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004868 +Opened: 2021-12-13 Investigator: INV-005 Severity: high +Customer: CUST-01468 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004869.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004869.txt new file mode 100644 index 0000000000000000000000000000000000000000..44e764b47e1d15bcb98f998aa43c996d2cbb54c4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004869.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004869 +Opened: 2022-01-03 Investigator: INV-004 Severity: high +Customer: CUST-01468 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004870.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004870.txt new file mode 100644 index 0000000000000000000000000000000000000000..67b0bea75d46d709041b9a16e07002d130cc2e46 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004870.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004870 +Opened: 2023-02-13 Investigator: INV-007 Severity: high +Customer: CUST-01468 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004871.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004871.txt new file mode 100644 index 0000000000000000000000000000000000000000..ca96e4512c87edf41c43e73d7ac3b6b5d4503bc3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004871.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004871 +Opened: 2021-11-04 Investigator: INV-006 Severity: high +Customer: CUST-01469 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004872.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004872.txt new file mode 100644 index 0000000000000000000000000000000000000000..297f6251bcc9307f1500749911396c9f94bf5371 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004872.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004872 +Opened: 2023-08-17 Investigator: INV-010 Severity: high +Customer: CUST-01469 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004873.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004873.txt new file mode 100644 index 0000000000000000000000000000000000000000..ce45828c85b8ffcd970ea0ab00aa8ae5f712222a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004873.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004873 +Opened: 2021-02-11 Investigator: INV-007 Severity: high +Customer: CUST-01470 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004874.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004874.txt new file mode 100644 index 0000000000000000000000000000000000000000..850b1486111d51d713554a67d554b4fc8bb93961 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004874.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004874 +Opened: 2021-03-02 Investigator: INV-004 Severity: high +Customer: CUST-01470 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004875.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004875.txt new file mode 100644 index 0000000000000000000000000000000000000000..c8fcbe4f39083c02020780632eaccb33bf3183bd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004875.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004875 +Opened: 2022-01-10 Investigator: INV-006 Severity: high +Customer: CUST-01470 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004876.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004876.txt new file mode 100644 index 0000000000000000000000000000000000000000..299a299c58cac4bb7ab705054674032bc89d6afd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004876.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004876 +Opened: 2022-06-03 Investigator: INV-009 Severity: critical +Customer: CUST-01470 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004877.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004877.txt new file mode 100644 index 0000000000000000000000000000000000000000..32bfc398d67c732dcf21e31fe581b2213a35db7b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004877.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004877 +Opened: 2024-04-10 Investigator: INV-001 Severity: high +Customer: CUST-01470 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type wire_to_cash generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004878.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004878.txt new file mode 100644 index 0000000000000000000000000000000000000000..00e8790c911c20e8b17ccdc19d82688a0bfef78e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004878.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004878 +Opened: 2024-08-02 Investigator: INV-007 Severity: high +Customer: CUST-01470 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type geo_anomaly generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004879.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004879.txt new file mode 100644 index 0000000000000000000000000000000000000000..c151a96a7121b3ddb20d2322d1e315c9f16410bd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004879.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004879 +Opened: 2024-10-02 Investigator: INV-001 Severity: high +Customer: CUST-01470 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004880.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004880.txt new file mode 100644 index 0000000000000000000000000000000000000000..c3307d12c9b76bb54fdfa382ef24647f9a7eac30 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004880.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004880 +Opened: 2022-09-23 Investigator: INV-005 Severity: high +Customer: CUST-01471 — ancillary_service operating in WA. + +1. BACKGROUND +The customer is a ancillary_service licensed in WA. At case open the point-in-time risk tier was low, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004881.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004881.txt new file mode 100644 index 0000000000000000000000000000000000000000..2ad205e8ac858bb87c37c3b848d7b27db78a23ca --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004881.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004881 +Opened: 2022-12-16 Investigator: INV-007 Severity: high +Customer: CUST-01471 — ancillary_service operating in WA. + +1. BACKGROUND +The customer is a ancillary_service licensed in WA. At case open the point-in-time risk tier was low, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004882.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004882.txt new file mode 100644 index 0000000000000000000000000000000000000000..714da7ad72ce297990a5937151b3c91d1ea6a17f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004882.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004882 +Opened: 2023-03-31 Investigator: INV-008 Severity: high +Customer: CUST-01471 — ancillary_service operating in WA. + +1. BACKGROUND +The customer is a ancillary_service licensed in WA. At case open the point-in-time risk tier was low, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004883.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004883.txt new file mode 100644 index 0000000000000000000000000000000000000000..18319efc15fae672b53d56716c5565cdc2223d19 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004883.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004883 +Opened: 2024-09-13 Investigator: INV-008 Severity: high +Customer: CUST-01472 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004884.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004884.txt new file mode 100644 index 0000000000000000000000000000000000000000..39f45cf28df3ad18c7e742d82822a401c5d00882 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004884.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004884 +Opened: 2021-10-13 Investigator: INV-001 Severity: high +Customer: CUST-01473 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004885.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004885.txt new file mode 100644 index 0000000000000000000000000000000000000000..f05637ea9d1b8ab2e73898959c947ed848752760 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004885.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004885 +Opened: 2022-02-14 Investigator: INV-004 Severity: high +Customer: CUST-01473 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type geo_anomaly generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004886.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004886.txt new file mode 100644 index 0000000000000000000000000000000000000000..e39f4b7f637be975447ab01910d474058138d84e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004886.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004886 +Opened: 2022-04-18 Investigator: INV-006 Severity: high +Customer: CUST-01473 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004887.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004887.txt new file mode 100644 index 0000000000000000000000000000000000000000..d879c2dde604829f6f2c4fbe1edd7b5ec9c74ebb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004887.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004887 +Opened: 2022-10-17 Investigator: INV-001 Severity: high +Customer: CUST-01473 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004888.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004888.txt new file mode 100644 index 0000000000000000000000000000000000000000..107e716b8c9b76575cab8fe19c29e45d305d96e5 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004888.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004888 +Opened: 2023-02-20 Investigator: INV-005 Severity: high +Customer: CUST-01473 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004889.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004889.txt new file mode 100644 index 0000000000000000000000000000000000000000..3e338135825a44fb44354a9c5c4386e3cabf43af --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004889.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004889 +Opened: 2023-04-03 Investigator: INV-006 Severity: high +Customer: CUST-01473 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004890.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004890.txt new file mode 100644 index 0000000000000000000000000000000000000000..86f1caaedf581ed25f95cb08b693894ddc277094 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004890.txt @@ -0,0 +1 @@ +Case CASE-004890 opened 2020-01-08 re: customer CUST-01474 (dispensary, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004891.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004891.txt new file mode 100644 index 0000000000000000000000000000000000000000..9eb5087c0bee5d3326c4b60c5a134000f1509b7b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004891.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004891 +Opened: 2022-02-03 Investigator: INV-002 Severity: high +Customer: CUST-01474 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004892.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004892.txt new file mode 100644 index 0000000000000000000000000000000000000000..816436bf57355018c23356ed2ddec9a30a3813ea --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004892.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004892 +Opened: 2023-12-04 Investigator: INV-008 Severity: high +Customer: CUST-01474 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004893.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004893.txt new file mode 100644 index 0000000000000000000000000000000000000000..21703dcabbafafaca25271a3029a04c873dbaa15 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004893.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004893 +Opened: 2021-06-25 Investigator: INV-002 Severity: critical +Customer: CUST-01475 — transport operating in CA. + +1. BACKGROUND +The customer is a transport licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004894.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004894.txt new file mode 100644 index 0000000000000000000000000000000000000000..9d9febc24cd38e9d237612bf9227e8f607ae15f2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004894.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004894 +Opened: 2021-08-23 Investigator: INV-002 Severity: high +Customer: CUST-01475 — transport operating in CA. + +1. BACKGROUND +The customer is a transport licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004895.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004895.txt new file mode 100644 index 0000000000000000000000000000000000000000..45325fd4cd7ece0b849a81c214182c13bd7264db --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004895.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004895 +Opened: 2022-02-07 Investigator: INV-005 Severity: high +Customer: CUST-01475 — transport operating in CA. + +1. BACKGROUND +The customer is a transport licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004896.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004896.txt new file mode 100644 index 0000000000000000000000000000000000000000..5c51238403799817683219125a6f8175d152e2aa --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004896.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004896 +Opened: 2022-09-08 Investigator: INV-005 Severity: critical +Customer: CUST-01475 — transport operating in CA. + +1. BACKGROUND +The customer is a transport licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004897.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004897.txt new file mode 100644 index 0000000000000000000000000000000000000000..089211835dd2813f4288730109262d25cccbb67f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004897.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004897 +Opened: 2023-10-05 Investigator: INV-006 Severity: high +Customer: CUST-01475 — transport operating in CA. + +1. BACKGROUND +The customer is a transport licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004898.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004898.txt new file mode 100644 index 0000000000000000000000000000000000000000..95050ee033f09c61ce9dd8b89db92c7be8394f1f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004898.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004898 +Opened: 2024-03-22 Investigator: INV-007 Severity: critical +Customer: CUST-01475 — transport operating in CA. + +1. BACKGROUND +The customer is a transport licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004899.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004899.txt new file mode 100644 index 0000000000000000000000000000000000000000..f2feb6d126f9c456af4d50aa0e80925ba8ea2acc --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004899.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004899 +Opened: 2023-05-08 Investigator: INV-007 Severity: high +Customer: CUST-01476 — manufacturing operating in WA. + +1. BACKGROUND +The customer is a manufacturing licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004900.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004900.txt new file mode 100644 index 0000000000000000000000000000000000000000..06d1cb3955fa07b08fdf5e4541455e8da1241754 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004900.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004900 +Opened: 2024-02-21 Investigator: INV-010 Severity: high +Customer: CUST-01476 — manufacturing operating in WA. + +1. BACKGROUND +The customer is a manufacturing licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004901.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004901.txt new file mode 100644 index 0000000000000000000000000000000000000000..2e0788f8bdeb78cb3691cec55b2f808b725dcca7 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004901.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004901 +Opened: 2024-05-16 Investigator: INV-004 Severity: high +Customer: CUST-01476 — manufacturing operating in WA. + +1. BACKGROUND +The customer is a manufacturing licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004902.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004902.txt new file mode 100644 index 0000000000000000000000000000000000000000..3a519881a1b6ab2bc347759dd188ba7f047afb99 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004902.txt @@ -0,0 +1 @@ +Case CASE-004902 opened 2020-08-04 re: customer CUST-01477 (dispensary, CO). Alert type: high_risk_jurisdiction. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-007. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004903.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004903.txt new file mode 100644 index 0000000000000000000000000000000000000000..c0bb0f02e823b54efcc277962764ca69fb5edd45 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004903.txt @@ -0,0 +1 @@ +Case CASE-004903 opened 2020-10-05 re: customer CUST-01477 (dispensary, CO). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-006. Suspicious activity identified consistent with structuring. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004904.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004904.txt new file mode 100644 index 0000000000000000000000000000000000000000..98c5a9881753219d28425fdc3d928586393f619f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004904.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004904 +Opened: 2021-04-09 Investigator: INV-005 Severity: high +Customer: CUST-01477 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004905.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004905.txt new file mode 100644 index 0000000000000000000000000000000000000000..adfdf181214c88bb6ea4d20f97787f122541eddd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004905.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004905 +Opened: 2021-05-03 Investigator: INV-008 Severity: high +Customer: CUST-01477 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004906.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004906.txt new file mode 100644 index 0000000000000000000000000000000000000000..0a1106f52efeac7a4c2de487fb8c9fe3624d92ba --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004906.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004906 +Opened: 2021-12-13 Investigator: INV-004 Severity: high +Customer: CUST-01478 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004907.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004907.txt new file mode 100644 index 0000000000000000000000000000000000000000..80fbced620b1d46e78019b3e770e6118d023298b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004907.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004907 +Opened: 2022-05-13 Investigator: INV-001 Severity: critical +Customer: CUST-01478 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004908.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004908.txt new file mode 100644 index 0000000000000000000000000000000000000000..37f17ee2882af4b0b6a265ca2e078b355d4fbc34 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004908.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004908 +Opened: 2023-02-06 Investigator: INV-004 Severity: critical +Customer: CUST-01478 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004909.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004909.txt new file mode 100644 index 0000000000000000000000000000000000000000..9c7d72e1f93d51b6f9ce57e6582e7454344d9ffb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004909.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004909 +Opened: 2024-10-07 Investigator: INV-001 Severity: high +Customer: CUST-01480 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004910.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004910.txt new file mode 100644 index 0000000000000000000000000000000000000000..8d0daaee445d35e0dd5c388b7caf14105ad2117d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004910.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004910 +Opened: 2021-06-11 Investigator: INV-002 Severity: critical +Customer: CUST-01481 — cultivation operating in MI. + +1. BACKGROUND +The customer is a cultivation licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004911.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004911.txt new file mode 100644 index 0000000000000000000000000000000000000000..6275b696bb491c3b6006859070e3027cf803e3c2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004911.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004911 +Opened: 2022-03-14 Investigator: INV-009 Severity: high +Customer: CUST-01481 — cultivation operating in MI. + +1. BACKGROUND +The customer is a cultivation licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004912.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004912.txt new file mode 100644 index 0000000000000000000000000000000000000000..d0532eb19eb0b59e2cdfc8adf034f1c36d958d27 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004912.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004912 +Opened: 2022-09-12 Investigator: INV-007 Severity: high +Customer: CUST-01481 — cultivation operating in MI. + +1. BACKGROUND +The customer is a cultivation licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004913.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004913.txt new file mode 100644 index 0000000000000000000000000000000000000000..29d8f60223fd0945687ad84932cad0c5fab2360d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004913.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004913 +Opened: 2023-04-21 Investigator: INV-003 Severity: high +Customer: CUST-01481 — cultivation operating in MI. + +1. BACKGROUND +The customer is a cultivation licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004914.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004914.txt new file mode 100644 index 0000000000000000000000000000000000000000..4f10825eba549ff2ca0ee549401bd2b54a7322b7 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004914.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004914 +Opened: 2023-08-02 Investigator: INV-006 Severity: high +Customer: CUST-01481 — cultivation operating in MI. + +1. BACKGROUND +The customer is a cultivation licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004915.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004915.txt new file mode 100644 index 0000000000000000000000000000000000000000..6c29208691e91e7b3e0e8892de5bbdf86e448704 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004915.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004915 +Opened: 2024-05-07 Investigator: INV-007 Severity: high +Customer: CUST-01481 — cultivation operating in MI. + +1. BACKGROUND +The customer is a cultivation licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004916.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004916.txt new file mode 100644 index 0000000000000000000000000000000000000000..4d593d751cc6fe977a6391b33f1c2b73a7feff12 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004916.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004916 +Opened: 2024-09-06 Investigator: INV-009 Severity: high +Customer: CUST-01481 — cultivation operating in MI. + +1. BACKGROUND +The customer is a cultivation licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004917.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004917.txt new file mode 100644 index 0000000000000000000000000000000000000000..5cbc17ac0e20fab11472dd6906aa48fa6eb03d53 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004917.txt @@ -0,0 +1 @@ +Case CASE-004917 opened 2020-01-06 re: customer CUST-01482 (dispensary, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004918.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004918.txt new file mode 100644 index 0000000000000000000000000000000000000000..c409653b533cc1f5d7c7ba5b9f44bc70511ba0a1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004918.txt @@ -0,0 +1 @@ +Case CASE-004918 opened 2020-02-03 re: customer CUST-01482 (dispensary, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004919.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004919.txt new file mode 100644 index 0000000000000000000000000000000000000000..35a269f2066f31940effe235331fd4ccc903da3d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004919.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004919 +Opened: 2021-01-11 Investigator: INV-004 Severity: high +Customer: CUST-01482 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004920.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004920.txt new file mode 100644 index 0000000000000000000000000000000000000000..da06faf1aec911da9a79e0d0e9ccb2c817f809e0 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004920.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004920 +Opened: 2023-05-04 Investigator: INV-005 Severity: critical +Customer: CUST-01482 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004921.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004921.txt new file mode 100644 index 0000000000000000000000000000000000000000..14c6112337dbe3a669786b70fcb6a9de65ef3911 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004921.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004921 +Opened: 2023-12-08 Investigator: INV-003 Severity: high +Customer: CUST-01483 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004922.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004922.txt new file mode 100644 index 0000000000000000000000000000000000000000..16b5e8cf9f55395155b72de48eee03d63e6021e7 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004922.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004922 +Opened: 2022-08-11 Investigator: INV-008 Severity: high +Customer: CUST-01485 — manufacturing operating in NV. + +1. BACKGROUND +The customer is a manufacturing licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004923.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004923.txt new file mode 100644 index 0000000000000000000000000000000000000000..912a5b46bafdc91d9b8115fe4694d4b98d7f4f98 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004923.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004923 +Opened: 2023-02-08 Investigator: INV-001 Severity: high +Customer: CUST-01485 — manufacturing operating in NV. + +1. BACKGROUND +The customer is a manufacturing licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004924.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004924.txt new file mode 100644 index 0000000000000000000000000000000000000000..c2b09c4e54d8146eccab7085e47b2b549f38d99b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004924.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004924 +Opened: 2023-04-21 Investigator: INV-009 Severity: high +Customer: CUST-01485 — manufacturing operating in NV. + +1. BACKGROUND +The customer is a manufacturing licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004925.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004925.txt new file mode 100644 index 0000000000000000000000000000000000000000..9ad167a42f6188358515f3772083333f3608861d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004925.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004925 +Opened: 2023-06-07 Investigator: INV-003 Severity: high +Customer: CUST-01485 — manufacturing operating in NV. + +1. BACKGROUND +The customer is a manufacturing licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004926.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004926.txt new file mode 100644 index 0000000000000000000000000000000000000000..ac17fc43b18e16cc18cec510c1f6af76d421b40b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004926.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004926 +Opened: 2024-08-02 Investigator: INV-003 Severity: high +Customer: CUST-01485 — manufacturing operating in NV. + +1. BACKGROUND +The customer is a manufacturing licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004927.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004927.txt new file mode 100644 index 0000000000000000000000000000000000000000..0ef20840e8a8fe0a6f554cf503930fec85fb62a6 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004927.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004927 +Opened: 2024-09-16 Investigator: INV-009 Severity: high +Customer: CUST-01485 — manufacturing operating in NV. + +1. BACKGROUND +The customer is a manufacturing licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004928.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004928.txt new file mode 100644 index 0000000000000000000000000000000000000000..ee759595d725c08dadbf2b8b30ec55f2a1876770 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004928.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004928 +Opened: 2023-07-13 Investigator: INV-006 Severity: moderate +Customer: CUST-01488 — testing_lab operating in WA. + +1. BACKGROUND +The customer is a testing_lab licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004929.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004929.txt new file mode 100644 index 0000000000000000000000000000000000000000..b0111b8599cdbec78ebd0432c7c3df68c28d7099 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004929.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004929 +Opened: 2023-08-01 Investigator: INV-010 Severity: high +Customer: CUST-01488 — testing_lab operating in WA. + +1. BACKGROUND +The customer is a testing_lab licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004930.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004930.txt new file mode 100644 index 0000000000000000000000000000000000000000..7475d0e5fdad2093f6a77b14f0a4d55b0a1d3c89 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004930.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004930 +Opened: 2023-09-06 Investigator: INV-001 Severity: high +Customer: CUST-01488 — testing_lab operating in WA. + +1. BACKGROUND +The customer is a testing_lab licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004931.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004931.txt new file mode 100644 index 0000000000000000000000000000000000000000..bcabb4ecaafa661109e1c774b1c3892ffe40e790 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004931.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004931 +Opened: 2023-11-10 Investigator: INV-009 Severity: high +Customer: CUST-01488 — testing_lab operating in WA. + +1. BACKGROUND +The customer is a testing_lab licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004932.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004932.txt new file mode 100644 index 0000000000000000000000000000000000000000..91b2ff8b9b079ebc8802014b0960e9926f6d8ef2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004932.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004932 +Opened: 2024-01-02 Investigator: INV-004 Severity: high +Customer: CUST-01488 — testing_lab operating in WA. + +1. BACKGROUND +The customer is a testing_lab licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004933.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004933.txt new file mode 100644 index 0000000000000000000000000000000000000000..b8ac541b16c7c6b6a67b52e4fd244612710d032c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004933.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004933 +Opened: 2024-04-05 Investigator: INV-008 Severity: high +Customer: CUST-01488 — testing_lab operating in WA. + +1. BACKGROUND +The customer is a testing_lab licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004934.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004934.txt new file mode 100644 index 0000000000000000000000000000000000000000..aa3303a5cf615a2a985d0560df637f31390c0292 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004934.txt @@ -0,0 +1 @@ +Case CASE-004934 opened 2020-11-10 re: customer CUST-01489 (delivery, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004935.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004935.txt new file mode 100644 index 0000000000000000000000000000000000000000..87fdb47ba4fde348048681927510ce52b18b4ebb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004935.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004935 +Opened: 2021-05-11 Investigator: INV-003 Severity: high +Customer: CUST-01489 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004936.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004936.txt new file mode 100644 index 0000000000000000000000000000000000000000..4649f3b334f62c78bfd1f534b663990f5e4db737 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004936.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004936 +Opened: 2021-09-13 Investigator: INV-006 Severity: critical +Customer: CUST-01489 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004937.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004937.txt new file mode 100644 index 0000000000000000000000000000000000000000..7885110a884a717f54c7363a32d982f42cedf5ee --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004937.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004937 +Opened: 2022-07-19 Investigator: INV-008 Severity: critical +Customer: CUST-01489 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004938.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004938.txt new file mode 100644 index 0000000000000000000000000000000000000000..80099d334a9c4e2883d3cedb8e556013123902d9 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004938.txt @@ -0,0 +1 @@ +Case CASE-004938 opened 2020-12-02 re: customer CUST-01490 (cultivation, CO). Alert type: cross_state_transfer. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-002. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004939.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004939.txt new file mode 100644 index 0000000000000000000000000000000000000000..a5bed1655b057022ee7756b32936f2c633547f10 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004939.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004939 +Opened: 2021-02-15 Investigator: INV-005 Severity: high +Customer: CUST-01490 — cultivation operating in CO. + +1. BACKGROUND +The customer is a cultivation licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004940.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004940.txt new file mode 100644 index 0000000000000000000000000000000000000000..6f8a248c318a9d48bdba1d07e4ec992c91ec5148 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004940.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004940 +Opened: 2021-04-05 Investigator: INV-007 Severity: high +Customer: CUST-01490 — cultivation operating in CO. + +1. BACKGROUND +The customer is a cultivation licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004941.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004941.txt new file mode 100644 index 0000000000000000000000000000000000000000..61f2cc6851392e5ef0dbb59a78f6962234364294 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004941.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004941 +Opened: 2022-08-11 Investigator: INV-006 Severity: high +Customer: CUST-01490 — cultivation operating in CO. + +1. BACKGROUND +The customer is a cultivation licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004942.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004942.txt new file mode 100644 index 0000000000000000000000000000000000000000..c44b24bf2c46e04984d84ad90161abfcc06068fa --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004942.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004942 +Opened: 2023-11-08 Investigator: INV-007 Severity: critical +Customer: CUST-01490 — cultivation operating in CO. + +1. BACKGROUND +The customer is a cultivation licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004943.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004943.txt new file mode 100644 index 0000000000000000000000000000000000000000..5e8c65bd004d1bc5d2e0e5c5f76f2a1347f9ffbf --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004943.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004943 +Opened: 2024-02-13 Investigator: INV-003 Severity: high +Customer: CUST-01490 — cultivation operating in CO. + +1. BACKGROUND +The customer is a cultivation licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004944.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004944.txt new file mode 100644 index 0000000000000000000000000000000000000000..c1de00029d052964e349c653f6c9e7cdf4fc066d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004944.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004944 +Opened: 2024-10-07 Investigator: INV-003 Severity: critical +Customer: CUST-01490 — cultivation operating in CO. + +1. BACKGROUND +The customer is a cultivation licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004945.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004945.txt new file mode 100644 index 0000000000000000000000000000000000000000..814a32e4480076db058288a3aa79eac9a08e193f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004945.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004945 +Opened: 2021-01-26 Investigator: INV-001 Severity: critical +Customer: CUST-01492 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004946.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004946.txt new file mode 100644 index 0000000000000000000000000000000000000000..5b3800492ae3635c6099c885a4458ffb7bf5d3bb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004946.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004946 +Opened: 2021-11-08 Investigator: INV-007 Severity: high +Customer: CUST-01492 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004947.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004947.txt new file mode 100644 index 0000000000000000000000000000000000000000..9ba8cf48c97e3299177c5859fc5feaa2009958a4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004947.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004947 +Opened: 2022-03-14 Investigator: INV-009 Severity: high +Customer: CUST-01492 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004948.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004948.txt new file mode 100644 index 0000000000000000000000000000000000000000..7bb1b56fa5144a828519b337077b5680723f05d1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004948.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004948 +Opened: 2022-08-05 Investigator: INV-003 Severity: high +Customer: CUST-01492 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004949.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004949.txt new file mode 100644 index 0000000000000000000000000000000000000000..f59b15f89ab40dc3deca6c8f3d0059169d7e2706 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004949.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004949 +Opened: 2022-09-09 Investigator: INV-008 Severity: high +Customer: CUST-01492 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004950.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004950.txt new file mode 100644 index 0000000000000000000000000000000000000000..b960142c3cb714ce633f570e57d215fa5bb4afa4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004950.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004950 +Opened: 2022-11-21 Investigator: INV-004 Severity: high +Customer: CUST-01492 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004951.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004951.txt new file mode 100644 index 0000000000000000000000000000000000000000..c732b9c11b76136aa267df0d1f1a6da9a0406d92 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004951.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004951 +Opened: 2023-02-07 Investigator: INV-009 Severity: high +Customer: CUST-01492 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004952.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004952.txt new file mode 100644 index 0000000000000000000000000000000000000000..e436dee6d2fa598432b39e530e23cce5c8299d0e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004952.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004952 +Opened: 2023-03-08 Investigator: INV-005 Severity: high +Customer: CUST-01492 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004953.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004953.txt new file mode 100644 index 0000000000000000000000000000000000000000..ce97b29e58c0040c6d7365786ce48e14c5b7dd41 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004953.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004953 +Opened: 2022-02-08 Investigator: INV-007 Severity: high +Customer: CUST-01493 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004954.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004954.txt new file mode 100644 index 0000000000000000000000000000000000000000..13729d5e7b611d0c9b7daff0a13763f0be0874e2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004954.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004954 +Opened: 2022-10-10 Investigator: INV-001 Severity: high +Customer: CUST-01493 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type geo_anomaly generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004955.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004955.txt new file mode 100644 index 0000000000000000000000000000000000000000..02c511addc5a138f49f66dd9c716898c9895e870 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004955.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004955 +Opened: 2023-04-03 Investigator: INV-009 Severity: high +Customer: CUST-01493 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004956.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004956.txt new file mode 100644 index 0000000000000000000000000000000000000000..8d678e417831f1b04351edad2c13d21a7ac4e41b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004956.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004956 +Opened: 2024-03-11 Investigator: INV-010 Severity: critical +Customer: CUST-01493 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004957.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004957.txt new file mode 100644 index 0000000000000000000000000000000000000000..674cba034b95b64570af64ea3cfa1a192c2204bd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004957.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004957 +Opened: 2024-08-05 Investigator: INV-008 Severity: high +Customer: CUST-01493 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004958.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004958.txt new file mode 100644 index 0000000000000000000000000000000000000000..e2199a7e7dce69dd546acebb1f414d678708ff1b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004958.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004958 +Opened: 2022-10-19 Investigator: INV-006 Severity: high +Customer: CUST-01495 — distribution operating in WA. + +1. BACKGROUND +The customer is a distribution licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004959.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004959.txt new file mode 100644 index 0000000000000000000000000000000000000000..8a032bda8c8418ad1080d04cc3fd9b4f6ea5d619 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004959.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004959 +Opened: 2024-09-09 Investigator: INV-001 Severity: high +Customer: CUST-01497 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004960.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004960.txt new file mode 100644 index 0000000000000000000000000000000000000000..5d10bbb4655feb817e21f2c641162ea6f2549ccb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004960.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004960 +Opened: 2024-10-07 Investigator: INV-004 Severity: high +Customer: CUST-01498 — nursery operating in CO. + +1. BACKGROUND +The customer is a nursery licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004961.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004961.txt new file mode 100644 index 0000000000000000000000000000000000000000..26550cf5051824d489da8292394fb28b45936a2f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004961.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004961 +Opened: 2023-09-18 Investigator: INV-005 Severity: high +Customer: CUST-01501 — professional_service operating in CO. + +1. BACKGROUND +The customer is a professional_service licensed in CO. At case open the point-in-time risk tier was low, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004962.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004962.txt new file mode 100644 index 0000000000000000000000000000000000000000..985d3510e2b7d2d70256a6c2d5480de6d03a6c40 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004962.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004962 +Opened: 2024-04-12 Investigator: INV-007 Severity: high +Customer: CUST-01501 — professional_service operating in CO. + +1. BACKGROUND +The customer is a professional_service licensed in CO. At case open the point-in-time risk tier was low, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004963.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004963.txt new file mode 100644 index 0000000000000000000000000000000000000000..019a9f0eb064f2a4cc934b0430c8d4573145f27e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004963.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004963 +Opened: 2021-03-08 Investigator: INV-003 Severity: high +Customer: CUST-01502 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004964.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004964.txt new file mode 100644 index 0000000000000000000000000000000000000000..90f74fc7be26e0159f698f9b9867778f440461c9 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004964.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004964 +Opened: 2021-06-02 Investigator: INV-008 Severity: high +Customer: CUST-01502 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004965.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004965.txt new file mode 100644 index 0000000000000000000000000000000000000000..9591310834921b14a9540672c6ebbf89eade6a6a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004965.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004965 +Opened: 2021-11-05 Investigator: INV-003 Severity: high +Customer: CUST-01502 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004966.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004966.txt new file mode 100644 index 0000000000000000000000000000000000000000..383ac8b750db39f2ce0a22e6ce71fe68e52bc2fc --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004966.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004966 +Opened: 2022-03-16 Investigator: INV-004 Severity: critical +Customer: CUST-01502 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004967.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004967.txt new file mode 100644 index 0000000000000000000000000000000000000000..298c8eb27a6929b692b11751880f10b27ae52671 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004967.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004967 +Opened: 2022-06-14 Investigator: INV-006 Severity: critical +Customer: CUST-01502 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004968.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004968.txt new file mode 100644 index 0000000000000000000000000000000000000000..8610c9dd4d27d3a84d583448852923f572dbbbc0 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004968.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004968 +Opened: 2022-08-15 Investigator: INV-006 Severity: high +Customer: CUST-01502 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004969.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004969.txt new file mode 100644 index 0000000000000000000000000000000000000000..3284c8745c3f7ddb15c8a3e85afed97c218b933c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004969.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004969 +Opened: 2022-11-15 Investigator: INV-005 Severity: high +Customer: CUST-01502 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004970.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004970.txt new file mode 100644 index 0000000000000000000000000000000000000000..2e7fe35ca6ce583773fdd099a14446df8bf18c7c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004970.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004970 +Opened: 2021-02-12 Investigator: INV-005 Severity: high +Customer: CUST-01503 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004971.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004971.txt new file mode 100644 index 0000000000000000000000000000000000000000..8b3e2a04f6bae23ea3c573db1cb6b64ed273fafd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004971.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004971 +Opened: 2022-07-12 Investigator: INV-005 Severity: high +Customer: CUST-01503 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004972.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004972.txt new file mode 100644 index 0000000000000000000000000000000000000000..d04400cd34d558128b53a3238a3a29a93039e629 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004972.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004972 +Opened: 2022-10-10 Investigator: INV-008 Severity: high +Customer: CUST-01503 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004973.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004973.txt new file mode 100644 index 0000000000000000000000000000000000000000..0ab9860b7b8a008b0954ed4a3967e82624303613 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004973.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004973 +Opened: 2023-10-05 Investigator: INV-003 Severity: high +Customer: CUST-01503 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004974.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004974.txt new file mode 100644 index 0000000000000000000000000000000000000000..52b112783a7b960374a15af90c3da3bd37a05474 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004974.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004974 +Opened: 2024-03-07 Investigator: INV-009 Severity: high +Customer: CUST-01503 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004975.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004975.txt new file mode 100644 index 0000000000000000000000000000000000000000..df6f7071b9258561be2e11338c81aacd410deff3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004975.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004975 +Opened: 2024-08-05 Investigator: INV-004 Severity: high +Customer: CUST-01504 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004976.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004976.txt new file mode 100644 index 0000000000000000000000000000000000000000..175bb588202664422f483364402f758847b5e275 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004976.txt @@ -0,0 +1 @@ +Case CASE-004976 opened 2019-11-01 re: customer CUST-01505 (delivery, OR). Alert type: cash_threshold. 2 alert(s) reviewed. Risk tier at open: high. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004977.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004977.txt new file mode 100644 index 0000000000000000000000000000000000000000..ab34084c7ed8ae4f6729e26ae6cf77fc4957b06d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004977.txt @@ -0,0 +1 @@ +Case CASE-004977 opened 2020-09-03 re: customer CUST-01505 (delivery, OR). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004978.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004978.txt new file mode 100644 index 0000000000000000000000000000000000000000..d83f66f6760fe11bd25145bf4124914aa5048bfe --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004978.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004978 +Opened: 2021-03-08 Investigator: INV-004 Severity: critical +Customer: CUST-01505 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004979.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004979.txt new file mode 100644 index 0000000000000000000000000000000000000000..c14b8450635b526ad3323e660bd90a91378775fe --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004979.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004979 +Opened: 2022-10-12 Investigator: INV-006 Severity: high +Customer: CUST-01505 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004980.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004980.txt new file mode 100644 index 0000000000000000000000000000000000000000..3997f1115c4f096ed3d329a745b4bee8891c02bf --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004980.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004980 +Opened: 2022-12-05 Investigator: INV-005 Severity: high +Customer: CUST-01505 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004981.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004981.txt new file mode 100644 index 0000000000000000000000000000000000000000..a735e1d2620e7376ec2239480215c8cd480c2a65 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004981.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004981 +Opened: 2023-04-10 Investigator: INV-009 Severity: critical +Customer: CUST-01505 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004982.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004982.txt new file mode 100644 index 0000000000000000000000000000000000000000..d41893d23c099a1670ea1383721f8bf8eee5edea --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004982.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004982 +Opened: 2023-09-11 Investigator: INV-001 Severity: high +Customer: CUST-01505 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004983.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004983.txt new file mode 100644 index 0000000000000000000000000000000000000000..bfaaa284f88781d193982872e565c67ede66da5a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004983.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004983 +Opened: 2024-02-12 Investigator: INV-004 Severity: high +Customer: CUST-01505 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004984.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004984.txt new file mode 100644 index 0000000000000000000000000000000000000000..4fc0c542967851e003b026045580285819831f7b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004984.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004984 +Opened: 2024-05-02 Investigator: INV-010 Severity: critical +Customer: CUST-01505 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004985.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004985.txt new file mode 100644 index 0000000000000000000000000000000000000000..c31cfdeeb0500c9ee843e96b21b2415eeda729ab --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004985.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004985 +Opened: 2024-06-17 Investigator: INV-003 Severity: high +Customer: CUST-01505 — delivery operating in OR. + +1. BACKGROUND +The customer is a delivery licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004986.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004986.txt new file mode 100644 index 0000000000000000000000000000000000000000..8da229f79de1d02607e3adc9c53364ac76c4946c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004986.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004986 +Opened: 2022-05-06 Investigator: INV-003 Severity: high +Customer: CUST-01507 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004987.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004987.txt new file mode 100644 index 0000000000000000000000000000000000000000..13981eb433a07e70e6ba12a75bfd79a246f892e7 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004987.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004987 +Opened: 2022-08-16 Investigator: INV-003 Severity: high +Customer: CUST-01507 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004988.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004988.txt new file mode 100644 index 0000000000000000000000000000000000000000..bcaec1f401e86b632859401a7a7b03adebb111ff --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004988.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004988 +Opened: 2021-01-04 Investigator: INV-005 Severity: high +Customer: CUST-01508 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004989.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004989.txt new file mode 100644 index 0000000000000000000000000000000000000000..37912ca61964e48f34f9b0d073d0291f3daf969d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004989.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004989 +Opened: 2021-06-07 Investigator: INV-001 Severity: high +Customer: CUST-01508 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004990.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004990.txt new file mode 100644 index 0000000000000000000000000000000000000000..1b64130bae385dae1209a502a04b41b22a6748ce --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004990.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004990 +Opened: 2022-03-07 Investigator: INV-006 Severity: high +Customer: CUST-01508 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004991.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004991.txt new file mode 100644 index 0000000000000000000000000000000000000000..e7d5f088dbe7af0fe39d8b332c7cf12923a4a529 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004991.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004991 +Opened: 2022-07-06 Investigator: INV-006 Severity: high +Customer: CUST-01508 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004992.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004992.txt new file mode 100644 index 0000000000000000000000000000000000000000..48659cef330e41994cc1bfe889567b16bb9c26f1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004992.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004992 +Opened: 2024-11-04 Investigator: INV-007 Severity: high +Customer: CUST-01508 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cannabis_wire_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004993.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004993.txt new file mode 100644 index 0000000000000000000000000000000000000000..6c048901ad8d4aa14d4c078da8ed6dca451879ae --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004993.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004993 +Opened: 2021-06-10 Investigator: INV-007 Severity: high +Customer: CUST-01510 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type negative_news generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004994.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004994.txt new file mode 100644 index 0000000000000000000000000000000000000000..2d4056523812c7c9b2b2858efac3d3c5042a880a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004994.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004994 +Opened: 2022-03-24 Investigator: INV-006 Severity: critical +Customer: CUST-01510 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004995.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004995.txt new file mode 100644 index 0000000000000000000000000000000000000000..995fb2922ed806258435f39b9a55f9e0d5bb4581 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004995.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004995 +Opened: 2022-05-03 Investigator: INV-008 Severity: high +Customer: CUST-01510 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004996.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004996.txt new file mode 100644 index 0000000000000000000000000000000000000000..b92b7be16422b7a852fd2ec68d5e6a0a7fd58191 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004996.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004996 +Opened: 2022-06-27 Investigator: INV-004 Severity: high +Customer: CUST-01510 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004997.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004997.txt new file mode 100644 index 0000000000000000000000000000000000000000..1b949d5a0f9e56bc6b2f367209e7bb305de07a12 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004997.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004997 +Opened: 2022-08-02 Investigator: INV-001 Severity: high +Customer: CUST-01510 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004998.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004998.txt new file mode 100644 index 0000000000000000000000000000000000000000..fc3ead88f0203ffc6cf73fa17e3232d45bade34b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004998.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004998 +Opened: 2023-02-27 Investigator: INV-005 Severity: high +Customer: CUST-01510 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004999.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004999.txt new file mode 100644 index 0000000000000000000000000000000000000000..6798b01adff25768eab9abd598ff7d571237b3f3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-004999.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-004999 +Opened: 2023-05-15 Investigator: INV-008 Severity: high +Customer: CUST-01510 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005000.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005000.txt new file mode 100644 index 0000000000000000000000000000000000000000..a9010fe388e6c45aefe9f1aae4af7750db63c2c7 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005000.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005000 +Opened: 2024-03-01 Investigator: INV-001 Severity: high +Customer: CUST-01510 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005001.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005001.txt new file mode 100644 index 0000000000000000000000000000000000000000..0ed2871d9e08994bed3cf33f5931d9a60afca029 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005001.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005001 +Opened: 2024-04-01 Investigator: INV-009 Severity: high +Customer: CUST-01510 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005002.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005002.txt new file mode 100644 index 0000000000000000000000000000000000000000..d39470e88371f23afb44758b8011a52ffed54d8d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005002.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005002 +Opened: 2021-02-22 Investigator: INV-006 Severity: high +Customer: CUST-01511 — event_organizer operating in WA. + +1. BACKGROUND +The customer is a event_organizer licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005003.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005003.txt new file mode 100644 index 0000000000000000000000000000000000000000..911e5cd42467a78d2d83271ae5d0be9d29b72776 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005003.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005003 +Opened: 2022-01-17 Investigator: INV-007 Severity: high +Customer: CUST-01511 — event_organizer operating in WA. + +1. BACKGROUND +The customer is a event_organizer licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type geo_anomaly generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005004.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005004.txt new file mode 100644 index 0000000000000000000000000000000000000000..4f81224caf297d115cf4d03ccb60c549b92027ce --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005004.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005004 +Opened: 2022-03-08 Investigator: INV-005 Severity: high +Customer: CUST-01511 — event_organizer operating in WA. + +1. BACKGROUND +The customer is a event_organizer licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005005.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005005.txt new file mode 100644 index 0000000000000000000000000000000000000000..1a2d59084d0a5b2b5d0c39194ceebd0a44617897 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005005.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005005 +Opened: 2023-07-17 Investigator: INV-001 Severity: critical +Customer: CUST-01511 — event_organizer operating in WA. + +1. BACKGROUND +The customer is a event_organizer licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005006.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005006.txt new file mode 100644 index 0000000000000000000000000000000000000000..276ddf2c29d3a9d9409421b357e0474e41e7bcfc --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005006.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005006 +Opened: 2024-02-16 Investigator: INV-010 Severity: moderate +Customer: CUST-01511 — event_organizer operating in WA. + +1. BACKGROUND +The customer is a event_organizer licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005007.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005007.txt new file mode 100644 index 0000000000000000000000000000000000000000..23a45ea0431af00c54b6e12ad54695a55afd81f1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005007.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005007 +Opened: 2024-04-29 Investigator: INV-010 Severity: high +Customer: CUST-01511 — event_organizer operating in WA. + +1. BACKGROUND +The customer is a event_organizer licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005008.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005008.txt new file mode 100644 index 0000000000000000000000000000000000000000..579712d878408218f2e9f96d511c613ad10fdb9f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005008.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005008 +Opened: 2024-06-06 Investigator: INV-001 Severity: high +Customer: CUST-01511 — event_organizer operating in WA. + +1. BACKGROUND +The customer is a event_organizer licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005009.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005009.txt new file mode 100644 index 0000000000000000000000000000000000000000..bda05c37228dfa760921c01691034fea89bd64bf --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005009.txt @@ -0,0 +1 @@ +Case CASE-005009 opened 2019-09-10 re: customer CUST-01512 (dispensary, CO). Alert type: geo_anomaly. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-003. Suspicious activity identified consistent with geo_anomaly. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005010.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005010.txt new file mode 100644 index 0000000000000000000000000000000000000000..34063c4779e55d273459e3ad1356764434059107 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005010.txt @@ -0,0 +1 @@ +Case CASE-005010 opened 2020-01-02 re: customer CUST-01512 (dispensary, CO). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005011.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005011.txt new file mode 100644 index 0000000000000000000000000000000000000000..0ca8b465611c1698673ad219a0b0c88b45322876 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005011.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005011 +Opened: 2021-05-07 Investigator: INV-002 Severity: high +Customer: CUST-01512 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005012.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005012.txt new file mode 100644 index 0000000000000000000000000000000000000000..d3245a8555e16e9cb6dcaa5b0ed497865dc851af --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005012.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005012 +Opened: 2022-08-11 Investigator: INV-004 Severity: critical +Customer: CUST-01512 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005013.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005013.txt new file mode 100644 index 0000000000000000000000000000000000000000..710fccc1337cb2156a3eec489ee71bfaf02c0526 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005013.txt @@ -0,0 +1 @@ +Case CASE-005013 opened 2019-05-06 re: customer CUST-01513 (dispensary, CO). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005014.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005014.txt new file mode 100644 index 0000000000000000000000000000000000000000..29737638b8eb9d731bf2fb2c00a544a5cc88b043 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005014.txt @@ -0,0 +1 @@ +Case CASE-005014 opened 2020-01-06 re: customer CUST-01513 (dispensary, CO). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005015.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005015.txt new file mode 100644 index 0000000000000000000000000000000000000000..2070da8eaa5d311c4e6c5cc6f56fc035ef49629b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005015.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005015 +Opened: 2021-08-03 Investigator: INV-007 Severity: high +Customer: CUST-01513 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005016.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005016.txt new file mode 100644 index 0000000000000000000000000000000000000000..19f63f84cd424d2e9a81ba86236fbc0fd0e34fd4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005016.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005016 +Opened: 2022-07-06 Investigator: INV-009 Severity: critical +Customer: CUST-01513 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005017.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005017.txt new file mode 100644 index 0000000000000000000000000000000000000000..b1ee8e5ae0a978e35ca49b0984c99c7033712b7a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005017.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005017 +Opened: 2023-08-17 Investigator: INV-003 Severity: high +Customer: CUST-01513 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005018.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005018.txt new file mode 100644 index 0000000000000000000000000000000000000000..f4918afe1c78e2ffd3e96dc5d39ea8e451ff36be --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005018.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005018 +Opened: 2023-11-10 Investigator: INV-001 Severity: high +Customer: CUST-01513 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005019.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005019.txt new file mode 100644 index 0000000000000000000000000000000000000000..a23a6ebb5c52d7541868735b711445aebb606602 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005019.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005019 +Opened: 2024-05-06 Investigator: INV-006 Severity: high +Customer: CUST-01513 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005020.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005020.txt new file mode 100644 index 0000000000000000000000000000000000000000..80f45097a9cfaee679f93989c2a042bb903c944c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005020.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005020 +Opened: 2024-08-05 Investigator: INV-006 Severity: high +Customer: CUST-01513 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005021.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005021.txt new file mode 100644 index 0000000000000000000000000000000000000000..8049acdc660239b9500f460db9744d7daa3c70c7 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005021.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005021 +Opened: 2024-09-06 Investigator: INV-004 Severity: high +Customer: CUST-01513 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005022.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005022.txt new file mode 100644 index 0000000000000000000000000000000000000000..85042faecfc05a0b0c64016ccc4c5b74b8bc8f00 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005022.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005022 +Opened: 2022-09-05 Investigator: INV-007 Severity: high +Customer: CUST-01514 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005023.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005023.txt new file mode 100644 index 0000000000000000000000000000000000000000..3cffab8dde34ddbbfef8f61fb89d31ab74178a7d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005023.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005023 +Opened: 2022-12-06 Investigator: INV-003 Severity: high +Customer: CUST-01514 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005024.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005024.txt new file mode 100644 index 0000000000000000000000000000000000000000..0edc57ca278ed0783c533d35f294f4338f96f24c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005024.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005024 +Opened: 2023-03-13 Investigator: INV-007 Severity: high +Customer: CUST-01514 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005025.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005025.txt new file mode 100644 index 0000000000000000000000000000000000000000..8679c6d48e92aa99bf359f1580294de11320a36b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005025.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005025 +Opened: 2023-09-05 Investigator: INV-006 Severity: high +Customer: CUST-01514 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005026.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005026.txt new file mode 100644 index 0000000000000000000000000000000000000000..04e6e9aa98d6a51900c0d8088126738bc7b40b80 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005026.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005026 +Opened: 2024-05-09 Investigator: INV-003 Severity: high +Customer: CUST-01514 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005027.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005027.txt new file mode 100644 index 0000000000000000000000000000000000000000..999ada5e8fc44da2247bbf0e43a3e548bb5419eb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005027.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005027 +Opened: 2024-07-17 Investigator: INV-006 Severity: high +Customer: CUST-01514 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005028.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005028.txt new file mode 100644 index 0000000000000000000000000000000000000000..f864fdd6bc4c32e16c9ee9fb06e5d02b54b28048 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005028.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005028 +Opened: 2021-11-11 Investigator: INV-006 Severity: high +Customer: CUST-01515 — testing_lab operating in CO. + +1. BACKGROUND +The customer is a testing_lab licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005029.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005029.txt new file mode 100644 index 0000000000000000000000000000000000000000..aa16876a353246e18a2c5e68586687d79ca09639 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005029.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005029 +Opened: 2022-03-21 Investigator: INV-002 Severity: high +Customer: CUST-01515 — testing_lab operating in CO. + +1. BACKGROUND +The customer is a testing_lab licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005030.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005030.txt new file mode 100644 index 0000000000000000000000000000000000000000..e7f7c63188bbbab0817adaedcb64cf36b564b482 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005030.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005030 +Opened: 2022-05-30 Investigator: INV-003 Severity: high +Customer: CUST-01515 — testing_lab operating in CO. + +1. BACKGROUND +The customer is a testing_lab licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005031.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005031.txt new file mode 100644 index 0000000000000000000000000000000000000000..295528dd2cf765b9641804ba31b5bbf981182129 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005031.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005031 +Opened: 2022-11-25 Investigator: INV-005 Severity: high +Customer: CUST-01515 — testing_lab operating in CO. + +1. BACKGROUND +The customer is a testing_lab licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005032.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005032.txt new file mode 100644 index 0000000000000000000000000000000000000000..a3b3df7a695a80f8f0e960fb5ed18509e5be2c0a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005032.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005032 +Opened: 2023-02-09 Investigator: INV-006 Severity: high +Customer: CUST-01515 — testing_lab operating in CO. + +1. BACKGROUND +The customer is a testing_lab licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005033.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005033.txt new file mode 100644 index 0000000000000000000000000000000000000000..bb61692c46051f99b00caedbaff1b6dd6460ee03 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005033.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005033 +Opened: 2023-05-29 Investigator: INV-009 Severity: high +Customer: CUST-01515 — testing_lab operating in CO. + +1. BACKGROUND +The customer is a testing_lab licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005034.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005034.txt new file mode 100644 index 0000000000000000000000000000000000000000..952d9fcf86d4c6421e4595d7a734e8f3cf713c66 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005034.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005034 +Opened: 2023-09-25 Investigator: INV-007 Severity: high +Customer: CUST-01515 — testing_lab operating in CO. + +1. BACKGROUND +The customer is a testing_lab licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005035.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005035.txt new file mode 100644 index 0000000000000000000000000000000000000000..58141b9d03d3b594058f16f2488bb5601f5b25b8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005035.txt @@ -0,0 +1 @@ +Case CASE-005035 opened 2020-12-08 re: customer CUST-01517 (dispensary, MI). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005036.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005036.txt new file mode 100644 index 0000000000000000000000000000000000000000..3576c17e67e64235587784cd425a12630ea4af4b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005036.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005036 +Opened: 2021-01-12 Investigator: INV-006 Severity: critical +Customer: CUST-01517 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005037.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005037.txt new file mode 100644 index 0000000000000000000000000000000000000000..30fb1544b66c37550a43777793c8b099ba88b746 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005037.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005037 +Opened: 2021-10-05 Investigator: INV-005 Severity: high +Customer: CUST-01517 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005038.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005038.txt new file mode 100644 index 0000000000000000000000000000000000000000..70835b4d05a4f833cc90cd75e2b93f05411d09bb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005038.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005038 +Opened: 2022-02-03 Investigator: INV-001 Severity: high +Customer: CUST-01517 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005039.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005039.txt new file mode 100644 index 0000000000000000000000000000000000000000..18ab040187e6118c5bacc6d83dfa3af6b012d546 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005039.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005039 +Opened: 2022-07-06 Investigator: INV-004 Severity: critical +Customer: CUST-01517 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005040.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005040.txt new file mode 100644 index 0000000000000000000000000000000000000000..0fd02d8f588e522a1ee62512744f0ca93795a552 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005040.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005040 +Opened: 2023-03-02 Investigator: INV-005 Severity: high +Customer: CUST-01517 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005041.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005041.txt new file mode 100644 index 0000000000000000000000000000000000000000..f7363c67aed829826daa65aa75cfc1015a5a678c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005041.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005041 +Opened: 2024-06-12 Investigator: INV-008 Severity: high +Customer: CUST-01517 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005042.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005042.txt new file mode 100644 index 0000000000000000000000000000000000000000..a8c92fb33bab0a358a8b7058c6457e4e43bb0039 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005042.txt @@ -0,0 +1 @@ +Case CASE-005042 opened 2019-03-12 re: customer CUST-01518 (manufacturing, MI). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-002. Suspicious activity identified consistent with cash_threshold. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005043.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005043.txt new file mode 100644 index 0000000000000000000000000000000000000000..175af6239d3713ebaa39fc06eaf2ffd36439e56c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005043.txt @@ -0,0 +1 @@ +Case CASE-005043 opened 2019-09-05 re: customer CUST-01519 (delivery, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-003. Suspicious activity identified consistent with cash_threshold. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005044.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005044.txt new file mode 100644 index 0000000000000000000000000000000000000000..b1aa47653fa8b2f527c0bb97915876d30a2949c9 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005044.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005044 +Opened: 2021-10-04 Investigator: INV-008 Severity: high +Customer: CUST-01519 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005045.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005045.txt new file mode 100644 index 0000000000000000000000000000000000000000..721dd0709be94353f6cc2ae398e040abec7a824f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005045.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005045 +Opened: 2022-06-03 Investigator: INV-005 Severity: high +Customer: CUST-01519 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005046.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005046.txt new file mode 100644 index 0000000000000000000000000000000000000000..e0c0a955d017b25c9b4850900a06ba642e9b53f2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005046.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005046 +Opened: 2022-09-19 Investigator: INV-004 Severity: high +Customer: CUST-01519 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005047.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005047.txt new file mode 100644 index 0000000000000000000000000000000000000000..e32cebeb7f6d0c7b8cd2e9b63e03aa7f91cbf34f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005047.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005047 +Opened: 2024-01-09 Investigator: INV-009 Severity: high +Customer: CUST-01519 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005048.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005048.txt new file mode 100644 index 0000000000000000000000000000000000000000..d37f8e729866059a6a939bec7746927b3b379098 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005048.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005048 +Opened: 2024-05-09 Investigator: INV-004 Severity: high +Customer: CUST-01519 — delivery operating in CA. + +1. BACKGROUND +The customer is a delivery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005049.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005049.txt new file mode 100644 index 0000000000000000000000000000000000000000..425446b35c979b76e82220cc010a3be0a5dbfb15 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005049.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005049 +Opened: 2023-12-04 Investigator: INV-004 Severity: high +Customer: CUST-01520 — nursery operating in CO. + +1. BACKGROUND +The customer is a nursery licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005050.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005050.txt new file mode 100644 index 0000000000000000000000000000000000000000..c29b0af6e76f86a3ef93cc6bedd665bc6d3312cb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005050.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005050 +Opened: 2024-05-28 Investigator: INV-006 Severity: critical +Customer: CUST-01520 — nursery operating in CO. + +1. BACKGROUND +The customer is a nursery licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005051.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005051.txt new file mode 100644 index 0000000000000000000000000000000000000000..09688f22fa6ffec670169ef0c136c4020bb9cb38 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005051.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005051 +Opened: 2024-07-17 Investigator: INV-003 Severity: high +Customer: CUST-01520 — nursery operating in CO. + +1. BACKGROUND +The customer is a nursery licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005052.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005052.txt new file mode 100644 index 0000000000000000000000000000000000000000..914a278953cbca7d62436c219c4d0b5d1be3aabc --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005052.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005052 +Opened: 2024-09-30 Investigator: INV-001 Severity: high +Customer: CUST-01520 — nursery operating in CO. + +1. BACKGROUND +The customer is a nursery licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005053.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005053.txt new file mode 100644 index 0000000000000000000000000000000000000000..5de38202027ac4b785cfb6bd6b49549e6f6d6071 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005053.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005053 +Opened: 2022-12-07 Investigator: INV-009 Severity: critical +Customer: CUST-01521 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005054.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005054.txt new file mode 100644 index 0000000000000000000000000000000000000000..8ed18545ab335f1b29808934d2e78b822a14cd0f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005054.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005054 +Opened: 2024-09-27 Investigator: INV-003 Severity: high +Customer: CUST-01522 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005055.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005055.txt new file mode 100644 index 0000000000000000000000000000000000000000..bc3b2fe7681be29f0dc610bedc2fdc5261409e1c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005055.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005055 +Opened: 2024-04-25 Investigator: INV-008 Severity: high +Customer: CUST-01523 — transport operating in CO. + +1. BACKGROUND +The customer is a transport licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005056.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005056.txt new file mode 100644 index 0000000000000000000000000000000000000000..fd6627d79f64eabc124a22a69ac781595adb9ceb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005056.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005056 +Opened: 2024-01-15 Investigator: INV-007 Severity: high +Customer: CUST-01524 — manufacturing operating in NV. + +1. BACKGROUND +The customer is a manufacturing licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005057.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005057.txt new file mode 100644 index 0000000000000000000000000000000000000000..2470690cfe6c4610047ab8591bcf1dedd998892e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005057.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005057 +Opened: 2024-03-05 Investigator: INV-006 Severity: critical +Customer: CUST-01524 — manufacturing operating in NV. + +1. BACKGROUND +The customer is a manufacturing licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005058.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005058.txt new file mode 100644 index 0000000000000000000000000000000000000000..56beec2b50bdc16957085ba50558878a53606a49 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005058.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005058 +Opened: 2024-08-02 Investigator: INV-010 Severity: high +Customer: CUST-01524 — manufacturing operating in NV. + +1. BACKGROUND +The customer is a manufacturing licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005059.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005059.txt new file mode 100644 index 0000000000000000000000000000000000000000..a81ba60adeae77139191dab312c49f639197e16a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005059.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005059 +Opened: 2024-10-07 Investigator: INV-009 Severity: high +Customer: CUST-01525 — event_organizer operating in WA. + +1. BACKGROUND +The customer is a event_organizer licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type geo_anomaly generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005060.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005060.txt new file mode 100644 index 0000000000000000000000000000000000000000..5ae11c3e2b52e88250ebab5b0767113e4c34b469 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005060.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005060 +Opened: 2023-12-15 Investigator: INV-003 Severity: high +Customer: CUST-01526 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005061.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005061.txt new file mode 100644 index 0000000000000000000000000000000000000000..fd551a2f0928f2324bd9fc11d7225c69f7fa1396 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005061.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005061 +Opened: 2024-02-19 Investigator: INV-007 Severity: high +Customer: CUST-01526 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005062.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005062.txt new file mode 100644 index 0000000000000000000000000000000000000000..babe1e06e341b237d36b24c3130f28ec709d6c1b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005062.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005062 +Opened: 2024-06-11 Investigator: INV-007 Severity: high +Customer: CUST-01526 — testing_lab operating in CA. + +1. BACKGROUND +The customer is a testing_lab licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005063.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005063.txt new file mode 100644 index 0000000000000000000000000000000000000000..49b18c92a70ccb3fb8b87f7aeae8d4e624a4aa7c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005063.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005063 +Opened: 2024-03-08 Investigator: INV-009 Severity: high +Customer: CUST-01527 — dispensary operating in WA. + +1. BACKGROUND +The customer is a dispensary licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005064.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005064.txt new file mode 100644 index 0000000000000000000000000000000000000000..fc9700e078e80e41370eb45fa6c583447f0ebc8c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005064.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005064 +Opened: 2024-07-02 Investigator: INV-001 Severity: critical +Customer: CUST-01527 — dispensary operating in WA. + +1. BACKGROUND +The customer is a dispensary licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005065.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005065.txt new file mode 100644 index 0000000000000000000000000000000000000000..85cff6ae830c2553824a8ee0364f28c6b6d32d8e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005065.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005065 +Opened: 2024-11-08 Investigator: INV-008 Severity: high +Customer: CUST-01527 — dispensary operating in WA. + +1. BACKGROUND +The customer is a dispensary licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005066.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005066.txt new file mode 100644 index 0000000000000000000000000000000000000000..def25b06c6a1a377e37264d2da3fc8555762aa22 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005066.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005066 +Opened: 2023-07-03 Investigator: INV-005 Severity: high +Customer: CUST-01528 — professional_service operating in CO. + +1. BACKGROUND +The customer is a professional_service licensed in CO. At case open the point-in-time risk tier was low, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005067.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005067.txt new file mode 100644 index 0000000000000000000000000000000000000000..5da4aa1ea07219c053cf3934f5652a50535dc16c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005067.txt @@ -0,0 +1 @@ +Case CASE-005067 opened 2018-05-28 re: customer CUST-01529 (dispensary, MI). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-002. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005068.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005068.txt new file mode 100644 index 0000000000000000000000000000000000000000..1250dbab987cf0ab2eff8445498d7247e175d4b4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005068.txt @@ -0,0 +1 @@ +Case CASE-005068 opened 2019-04-12 re: customer CUST-01529 (dispensary, MI). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005069.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005069.txt new file mode 100644 index 0000000000000000000000000000000000000000..5d7d0109ab44cc72aeb2fad9fea673a49a45cc87 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005069.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005069 +Opened: 2021-02-03 Investigator: INV-005 Severity: high +Customer: CUST-01529 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005070.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005070.txt new file mode 100644 index 0000000000000000000000000000000000000000..51ec61761bed31a7d791c339fb704f2b3583fe2a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005070.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005070 +Opened: 2022-01-10 Investigator: INV-003 Severity: critical +Customer: CUST-01529 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005071.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005071.txt new file mode 100644 index 0000000000000000000000000000000000000000..a176b63527c13625536da271dfd935b082c17562 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005071.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005071 +Opened: 2023-05-08 Investigator: INV-005 Severity: critical +Customer: CUST-01529 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005072.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005072.txt new file mode 100644 index 0000000000000000000000000000000000000000..b5c87f704af7d069ac9a90ac41bd1011ebf0aed9 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005072.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005072 +Opened: 2023-09-04 Investigator: INV-003 Severity: high +Customer: CUST-01529 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005073.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005073.txt new file mode 100644 index 0000000000000000000000000000000000000000..d0491b3e17f380503376f70507bd4a0329722226 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005073.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005073 +Opened: 2024-05-07 Investigator: INV-009 Severity: high +Customer: CUST-01529 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005074.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005074.txt new file mode 100644 index 0000000000000000000000000000000000000000..42e02cb773c7caeb6d25617db8f29479d5d45c1d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005074.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005074 +Opened: 2024-08-05 Investigator: INV-001 Severity: critical +Customer: CUST-01529 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005075.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005075.txt new file mode 100644 index 0000000000000000000000000000000000000000..8bca3b0dbb21e67d309a68a7be8b41730b88dea0 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005075.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005075 +Opened: 2024-10-07 Investigator: INV-008 Severity: critical +Customer: CUST-01529 — dispensary operating in MI. + +1. BACKGROUND +The customer is a dispensary licensed in MI. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005076.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005076.txt new file mode 100644 index 0000000000000000000000000000000000000000..07282f8125d6da15e7ecb63819c60cc8e7f50b91 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005076.txt @@ -0,0 +1 @@ +Case CASE-005076 opened 2020-10-05 re: customer CUST-01530 (microbusiness, CO). Alert type: high_risk_jurisdiction. 2 alert(s) reviewed. Risk tier at open: high. Investigator: INV-002. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005077.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005077.txt new file mode 100644 index 0000000000000000000000000000000000000000..c6730e108acb2bb9216a8f7f4e8d41ddad4552be --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005077.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005077 +Opened: 2021-05-06 Investigator: INV-006 Severity: critical +Customer: CUST-01530 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005078.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005078.txt new file mode 100644 index 0000000000000000000000000000000000000000..117736349fb800b615ae6c3a42b2bbb9680777f5 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005078.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005078 +Opened: 2022-10-07 Investigator: INV-008 Severity: high +Customer: CUST-01530 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005079.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005079.txt new file mode 100644 index 0000000000000000000000000000000000000000..19da5d942a8746d60d433e38fbf9ab61da4f3b2a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005079.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005079 +Opened: 2023-02-02 Investigator: INV-001 Severity: moderate +Customer: CUST-01530 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005080.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005080.txt new file mode 100644 index 0000000000000000000000000000000000000000..5bbe5da6371699358379558f575eccbcc40a5b21 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005080.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005080 +Opened: 2023-03-14 Investigator: INV-006 Severity: high +Customer: CUST-01530 — microbusiness operating in CO. + +1. BACKGROUND +The customer is a microbusiness licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005081.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005081.txt new file mode 100644 index 0000000000000000000000000000000000000000..2f84324130a31447ec85436860061a9743f3f7ff --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005081.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005081 +Opened: 2021-05-07 Investigator: INV-008 Severity: high +Customer: CUST-01532 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005082.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005082.txt new file mode 100644 index 0000000000000000000000000000000000000000..1ef43583e25ad7f9a1006887b7d5aba5cc724110 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005082.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005082 +Opened: 2021-10-05 Investigator: INV-001 Severity: critical +Customer: CUST-01532 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005083.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005083.txt new file mode 100644 index 0000000000000000000000000000000000000000..a24c4d94117545f8b26f1cdc4c01ffda3a029a28 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005083.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005083 +Opened: 2021-11-04 Investigator: INV-007 Severity: high +Customer: CUST-01532 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005084.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005084.txt new file mode 100644 index 0000000000000000000000000000000000000000..ba846b4b9bffbb11b3be4a9399ef272aca13c485 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005084.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005084 +Opened: 2022-08-11 Investigator: INV-007 Severity: high +Customer: CUST-01532 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type negative_news generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005085.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005085.txt new file mode 100644 index 0000000000000000000000000000000000000000..a6263d5ae8845fc6ab332003fb77180d4ba9743e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005085.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005085 +Opened: 2023-09-13 Investigator: INV-009 Severity: high +Customer: CUST-01532 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005086.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005086.txt new file mode 100644 index 0000000000000000000000000000000000000000..abe07c6e35c625c973a674bf034c180284a294d4 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005086.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005086 +Opened: 2023-10-09 Investigator: INV-009 Severity: high +Customer: CUST-01532 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005087.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005087.txt new file mode 100644 index 0000000000000000000000000000000000000000..d58ae9d0d6da894d2ecf06c50d24198f28a11438 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005087.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005087 +Opened: 2023-12-11 Investigator: INV-004 Severity: high +Customer: CUST-01532 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005088.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005088.txt new file mode 100644 index 0000000000000000000000000000000000000000..f796360fc59a268acdd2c7faa6936491bbc87397 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005088.txt @@ -0,0 +1 @@ +Case CASE-005088 opened 2020-08-05 re: customer CUST-01533 (manufacturing, WA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005089.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005089.txt new file mode 100644 index 0000000000000000000000000000000000000000..6557febe4062770b7708306918b2f9e948548251 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005089.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005089 +Opened: 2023-03-07 Investigator: INV-003 Severity: high +Customer: CUST-01533 — manufacturing operating in WA. + +1. BACKGROUND +The customer is a manufacturing licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005090.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005090.txt new file mode 100644 index 0000000000000000000000000000000000000000..a3b21b7de82958b62de630d3db3d518692e54541 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005090.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005090 +Opened: 2021-08-13 Investigator: INV-007 Severity: high +Customer: CUST-01534 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005091.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005091.txt new file mode 100644 index 0000000000000000000000000000000000000000..a94cca4e4cf8bf0174bd90f4e4282732a0d7f88a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005091.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005091 +Opened: 2022-09-13 Investigator: INV-004 Severity: high +Customer: CUST-01534 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005092.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005092.txt new file mode 100644 index 0000000000000000000000000000000000000000..74bd1c778ec9be1b3ba4ecb08fe3a624ba0f6aa1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005092.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005092 +Opened: 2023-01-04 Investigator: INV-004 Severity: high +Customer: CUST-01535 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005093.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005093.txt new file mode 100644 index 0000000000000000000000000000000000000000..78b99dc32c514a14206e595661b483b9bc737ebb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005093.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005093 +Opened: 2023-11-03 Investigator: INV-003 Severity: high +Customer: CUST-01535 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005094.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005094.txt new file mode 100644 index 0000000000000000000000000000000000000000..b22102178c866c9f65526226477bdecf3edb82ab --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005094.txt @@ -0,0 +1 @@ +Case CASE-005094 opened 2019-10-07 re: customer CUST-01536 (cultivation, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-001. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005095.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005095.txt new file mode 100644 index 0000000000000000000000000000000000000000..493a1c6984d7530bdfd6c948fad81a6e5bb183ad --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005095.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005095 +Opened: 2021-04-12 Investigator: INV-007 Severity: high +Customer: CUST-01536 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005096.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005096.txt new file mode 100644 index 0000000000000000000000000000000000000000..e7067faccb5b63c04a1caa21763112fa7456df0b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005096.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005096 +Opened: 2021-08-09 Investigator: INV-005 Severity: high +Customer: CUST-01536 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005097.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005097.txt new file mode 100644 index 0000000000000000000000000000000000000000..64a43993930233677d4ef1e5b6b688a2520be2f2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005097.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005097 +Opened: 2022-02-14 Investigator: INV-002 Severity: high +Customer: CUST-01536 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005098.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005098.txt new file mode 100644 index 0000000000000000000000000000000000000000..45136b13658efe02981dc958b63784b8001844ba --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005098.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005098 +Opened: 2024-05-02 Investigator: INV-007 Severity: critical +Customer: CUST-01537 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005099.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005099.txt new file mode 100644 index 0000000000000000000000000000000000000000..81fa390db65cf8ee41cd68683e204562f431267c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005099.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005099 +Opened: 2024-08-05 Investigator: INV-004 Severity: high +Customer: CUST-01537 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005100.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005100.txt new file mode 100644 index 0000000000000000000000000000000000000000..56b4176d3c7fa20535e7f07fc8b7fb7a94ff9bfb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005100.txt @@ -0,0 +1 @@ +Case CASE-005100 opened 2020-05-11 re: customer CUST-01538 (dispensary, OR). Alert type: high_risk_jurisdiction. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-002. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005101.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005101.txt new file mode 100644 index 0000000000000000000000000000000000000000..1cfe9486005f7429733cc2ccc57abf88a141bf46 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005101.txt @@ -0,0 +1 @@ +Case CASE-005101 opened 2020-07-02 re: customer CUST-01538 (dispensary, OR). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005102.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005102.txt new file mode 100644 index 0000000000000000000000000000000000000000..d158b476d0c7aa2bcfbd30cb231ff8727bbe35a2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005102.txt @@ -0,0 +1 @@ +Case CASE-005102 opened 2020-12-07 re: customer CUST-01538 (dispensary, OR). Alert type: cross_state_transfer. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-001. Suspicious activity identified consistent with cross_state_transfer. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005103.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005103.txt new file mode 100644 index 0000000000000000000000000000000000000000..f07bfdb717fff60321687052b8694a44458832f3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005103.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005103 +Opened: 2021-01-11 Investigator: INV-002 Severity: critical +Customer: CUST-01538 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005104.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005104.txt new file mode 100644 index 0000000000000000000000000000000000000000..f179e3c8e97a17c90b5bb91f4a47111e71778c34 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005104.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005104 +Opened: 2022-09-06 Investigator: INV-006 Severity: high +Customer: CUST-01538 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005105.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005105.txt new file mode 100644 index 0000000000000000000000000000000000000000..fc62b3bdcc538ebead1f2df41437465d892e2034 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005105.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005105 +Opened: 2022-11-07 Investigator: INV-009 Severity: high +Customer: CUST-01538 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005106.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005106.txt new file mode 100644 index 0000000000000000000000000000000000000000..43934b914f18cfd2a1b8d2e594357bc258eb5edf --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005106.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005106 +Opened: 2024-04-08 Investigator: INV-009 Severity: critical +Customer: CUST-01538 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005107.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005107.txt new file mode 100644 index 0000000000000000000000000000000000000000..1a4f995443cf351df0746f22c7ba48e2411dc914 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005107.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005107 +Opened: 2021-06-07 Investigator: INV-004 Severity: high +Customer: CUST-01539 — manufacturing operating in NV. + +1. BACKGROUND +The customer is a manufacturing licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005108.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005108.txt new file mode 100644 index 0000000000000000000000000000000000000000..ff1b86b6563209d8bd728cbcd972ede7b8f22f02 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005108.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005108 +Opened: 2022-03-21 Investigator: INV-009 Severity: critical +Customer: CUST-01539 — manufacturing operating in NV. + +1. BACKGROUND +The customer is a manufacturing licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type geo_anomaly generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005109.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005109.txt new file mode 100644 index 0000000000000000000000000000000000000000..7db4c5c2b342cce330793d8a0e51f8fd4774afcc --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005109.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005109 +Opened: 2023-07-05 Investigator: INV-004 Severity: high +Customer: CUST-01542 — dispensary operating in WA. + +1. BACKGROUND +The customer is a dispensary licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005110.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005110.txt new file mode 100644 index 0000000000000000000000000000000000000000..7e221d572cf79896c7a075a65367c06f311a775f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005110.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005110 +Opened: 2023-08-10 Investigator: INV-006 Severity: high +Customer: CUST-01542 — dispensary operating in WA. + +1. BACKGROUND +The customer is a dispensary licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005111.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005111.txt new file mode 100644 index 0000000000000000000000000000000000000000..19203fdcef203b57f5a8348ee3d21563c269f9cd --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005111.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005111 +Opened: 2024-09-20 Investigator: INV-007 Severity: moderate +Customer: CUST-01542 — dispensary operating in WA. + +1. BACKGROUND +The customer is a dispensary licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005112.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005112.txt new file mode 100644 index 0000000000000000000000000000000000000000..383eab9253e382c506d4d925ad2a3b05b5197f19 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005112.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005112 +Opened: 2021-11-08 Investigator: INV-003 Severity: high +Customer: CUST-01543 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005113.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005113.txt new file mode 100644 index 0000000000000000000000000000000000000000..1202f78ca77f75e089259af26958019af099c950 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005113.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005113 +Opened: 2021-12-10 Investigator: INV-005 Severity: high +Customer: CUST-01543 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type geo_anomaly generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005114.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005114.txt new file mode 100644 index 0000000000000000000000000000000000000000..a6b19af65027c81114eeaeb8056e1b4eebbcac46 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005114.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005114 +Opened: 2022-02-16 Investigator: INV-007 Severity: high +Customer: CUST-01543 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005115.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005115.txt new file mode 100644 index 0000000000000000000000000000000000000000..b78fe1c8aac78a233b6da9f8f9779876f77d08f2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005115.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005115 +Opened: 2022-10-12 Investigator: INV-009 Severity: high +Customer: CUST-01543 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005116.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005116.txt new file mode 100644 index 0000000000000000000000000000000000000000..43dabf3388738daf61ec7b339262241d7cdace69 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005116.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005116 +Opened: 2024-04-09 Investigator: INV-010 Severity: high +Customer: CUST-01543 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005117.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005117.txt new file mode 100644 index 0000000000000000000000000000000000000000..d57f750cbf96d910958e693a9d9a9778f1c39d31 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005117.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005117 +Opened: 2023-09-08 Investigator: INV-009 Severity: high +Customer: CUST-01544 — ancillary_service operating in CA. + +1. BACKGROUND +The customer is a ancillary_service licensed in CA. At case open the point-in-time risk tier was low, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005118.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005118.txt new file mode 100644 index 0000000000000000000000000000000000000000..8cc6b86b1936028c51a2b51cdc7b3fe6702d274d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005118.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005118 +Opened: 2022-06-27 Investigator: INV-005 Severity: critical +Customer: CUST-01545 — nursery operating in WA. + +1. BACKGROUND +The customer is a nursery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005119.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005119.txt new file mode 100644 index 0000000000000000000000000000000000000000..b62696c6b926c61d683e469eb817b1dcc35bfcb2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005119.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005119 +Opened: 2022-10-10 Investigator: INV-003 Severity: high +Customer: CUST-01545 — nursery operating in WA. + +1. BACKGROUND +The customer is a nursery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005120.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005120.txt new file mode 100644 index 0000000000000000000000000000000000000000..b809602b5bef696e2b1faa1e147d44a8f7409438 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005120.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005120 +Opened: 2023-01-12 Investigator: INV-004 Severity: critical +Customer: CUST-01545 — nursery operating in WA. + +1. BACKGROUND +The customer is a nursery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005121.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005121.txt new file mode 100644 index 0000000000000000000000000000000000000000..887de55f6d9d1a5de90f2f1b006c6818fd2b3408 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005121.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005121 +Opened: 2023-06-07 Investigator: INV-003 Severity: high +Customer: CUST-01545 — nursery operating in WA. + +1. BACKGROUND +The customer is a nursery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005122.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005122.txt new file mode 100644 index 0000000000000000000000000000000000000000..5f296a79465a59f379f900f49be2cb5e06340d1b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005122.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005122 +Opened: 2023-11-27 Investigator: INV-010 Severity: high +Customer: CUST-01545 — nursery operating in WA. + +1. BACKGROUND +The customer is a nursery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005123.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005123.txt new file mode 100644 index 0000000000000000000000000000000000000000..d9b7f57878fd3c8eaeac31971b806a40a7862c9e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005123.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005123 +Opened: 2023-12-25 Investigator: INV-008 Severity: high +Customer: CUST-01545 — nursery operating in WA. + +1. BACKGROUND +The customer is a nursery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005124.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005124.txt new file mode 100644 index 0000000000000000000000000000000000000000..030bde559983f55b55c63b8fee9e14d4949e6dda --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005124.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005124 +Opened: 2024-04-12 Investigator: INV-010 Severity: high +Customer: CUST-01545 — nursery operating in WA. + +1. BACKGROUND +The customer is a nursery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005125.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005125.txt new file mode 100644 index 0000000000000000000000000000000000000000..6997cc9d75aa871c5ccd500a67550eb12ce93755 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005125.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005125 +Opened: 2024-08-19 Investigator: INV-010 Severity: high +Customer: CUST-01545 — nursery operating in WA. + +1. BACKGROUND +The customer is a nursery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005126.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005126.txt new file mode 100644 index 0000000000000000000000000000000000000000..19d81df21c4c24e834c7240cecb1ed65df68dae5 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005126.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005126 +Opened: 2024-09-16 Investigator: INV-008 Severity: high +Customer: CUST-01545 — nursery operating in WA. + +1. BACKGROUND +The customer is a nursery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005127.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005127.txt new file mode 100644 index 0000000000000000000000000000000000000000..c348324fb78d21631074315da5d4e02089dd36a1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005127.txt @@ -0,0 +1 @@ +Case CASE-005127 opened 2018-06-29 re: customer CUST-01546 (manufacturing, CA). Alert type: cash_threshold. 3 alert(s) reviewed. Risk tier at open: high. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005128.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005128.txt new file mode 100644 index 0000000000000000000000000000000000000000..5a9f7474a5fdeafcd6aac0a703509ab6fa7cb567 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005128.txt @@ -0,0 +1 @@ +Case CASE-005128 opened 2019-05-09 re: customer CUST-01546 (manufacturing, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005129.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005129.txt new file mode 100644 index 0000000000000000000000000000000000000000..0e84133646e84531e90d1fb62eb76479b48e5648 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005129.txt @@ -0,0 +1 @@ +Case CASE-005129 opened 2020-06-04 re: customer CUST-01546 (manufacturing, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-006. Suspicious activity identified consistent with cash_threshold. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005130.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005130.txt new file mode 100644 index 0000000000000000000000000000000000000000..8fe3391884b681ae5d8ef2ef1c1171196fb4c691 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005130.txt @@ -0,0 +1 @@ +Case CASE-005130 opened 2020-08-04 re: customer CUST-01546 (manufacturing, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-007. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005131.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005131.txt new file mode 100644 index 0000000000000000000000000000000000000000..847d977b662b93684560dd393402192be11d4a93 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005131.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005131 +Opened: 2021-09-15 Investigator: INV-005 Severity: high +Customer: CUST-01546 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005132.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005132.txt new file mode 100644 index 0000000000000000000000000000000000000000..c238af19cc4e7a0012bfc15dd8c9f69af8864a2d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005132.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005132 +Opened: 2022-10-12 Investigator: INV-001 Severity: moderate +Customer: CUST-01546 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type wire_to_cash generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005133.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005133.txt new file mode 100644 index 0000000000000000000000000000000000000000..0912cabb59cc12935e22ece87f091e0d99547766 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005133.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005133 +Opened: 2023-04-13 Investigator: INV-003 Severity: high +Customer: CUST-01546 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005134.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005134.txt new file mode 100644 index 0000000000000000000000000000000000000000..5d27f2a70b8cb85a9ee6eb754bb733c4b6ddbcae --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005134.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005134 +Opened: 2024-05-14 Investigator: INV-010 Severity: high +Customer: CUST-01546 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005135.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005135.txt new file mode 100644 index 0000000000000000000000000000000000000000..bff6d533324761fdba08f9187294cd8cd6f11d9f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005135.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005135 +Opened: 2024-09-20 Investigator: INV-004 Severity: high +Customer: CUST-01547 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005136.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005136.txt new file mode 100644 index 0000000000000000000000000000000000000000..15ea19675cf0523c4e4c117f14cbbaa5a6291d9e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005136.txt @@ -0,0 +1 @@ +Case CASE-005136 opened 2019-05-06 re: customer CUST-01548 (distribution, CA). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005137.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005137.txt new file mode 100644 index 0000000000000000000000000000000000000000..25cb3e334173da8e04c4927965001b1f0606b28c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005137.txt @@ -0,0 +1 @@ +Case CASE-005137 opened 2019-08-13 re: customer CUST-01548 (distribution, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005138.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005138.txt new file mode 100644 index 0000000000000000000000000000000000000000..75175020a4ccb88c7f3f7ad5150f63e8fe3928b2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005138.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005138 +Opened: 2021-02-08 Investigator: INV-005 Severity: high +Customer: CUST-01548 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005139.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005139.txt new file mode 100644 index 0000000000000000000000000000000000000000..cd00ea741fddf9fd142736ea9c8229a61a5d9180 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005139.txt @@ -0,0 +1 @@ +Case CASE-005139 opened 2020-10-05 re: customer CUST-01549 (testing_lab, MI). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-006. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005140.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005140.txt new file mode 100644 index 0000000000000000000000000000000000000000..39018c18a512088451868764657589d8b19dc4d9 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005140.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005140 +Opened: 2021-01-18 Investigator: INV-005 Severity: high +Customer: CUST-01549 — testing_lab operating in MI. + +1. BACKGROUND +The customer is a testing_lab licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005141.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005141.txt new file mode 100644 index 0000000000000000000000000000000000000000..3e069ece5214a2b9895f6f7b913d017853b37c8c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005141.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005141 +Opened: 2021-03-22 Investigator: INV-002 Severity: critical +Customer: CUST-01549 — testing_lab operating in MI. + +1. BACKGROUND +The customer is a testing_lab licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005142.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005142.txt new file mode 100644 index 0000000000000000000000000000000000000000..65260110a88035a03cc27c21b433cd2511b16e31 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005142.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005142 +Opened: 2024-04-08 Investigator: INV-007 Severity: critical +Customer: CUST-01550 — event_organizer operating in OR. + +1. BACKGROUND +The customer is a event_organizer licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005143.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005143.txt new file mode 100644 index 0000000000000000000000000000000000000000..4920b67e028c2cedaa1b3e5df14dccc902528738 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005143.txt @@ -0,0 +1 @@ +Case CASE-005143 opened 2020-11-26 re: customer CUST-01551 (manufacturing, OR). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-006. Suspicious activity identified consistent with cash_threshold. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005144.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005144.txt new file mode 100644 index 0000000000000000000000000000000000000000..3511bd34c62677278738839f3c9fc3a59dcbd3c7 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005144.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005144 +Opened: 2021-01-11 Investigator: INV-005 Severity: high +Customer: CUST-01551 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005145.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005145.txt new file mode 100644 index 0000000000000000000000000000000000000000..36460aa80689d0fff1b02b400711d7587c9b284a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005145.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005145 +Opened: 2021-05-17 Investigator: INV-006 Severity: high +Customer: CUST-01551 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005146.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005146.txt new file mode 100644 index 0000000000000000000000000000000000000000..ccd30b2df3f57ba84c725e0b74fa575fdbf1aa41 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005146.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005146 +Opened: 2022-05-05 Investigator: INV-003 Severity: critical +Customer: CUST-01551 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005147.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005147.txt new file mode 100644 index 0000000000000000000000000000000000000000..58bd8299bf43ccba4aa8496e4c0682b7389154c2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005147.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005147 +Opened: 2023-03-20 Investigator: INV-008 Severity: high +Customer: CUST-01551 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005148.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005148.txt new file mode 100644 index 0000000000000000000000000000000000000000..336c1a14d6683f629e253ec0b7545cd26e2c1428 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005148.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005148 +Opened: 2024-01-15 Investigator: INV-001 Severity: high +Customer: CUST-01551 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005149.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005149.txt new file mode 100644 index 0000000000000000000000000000000000000000..c142f8823c7311352b1de8f2c7f5e1a2eec68883 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005149.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005149 +Opened: 2024-08-05 Investigator: INV-007 Severity: high +Customer: CUST-01552 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005150.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005150.txt new file mode 100644 index 0000000000000000000000000000000000000000..0ef9c80dc69c4b487bf160e07d6d92506a9e226f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005150.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005150 +Opened: 2024-09-30 Investigator: INV-006 Severity: high +Customer: CUST-01552 — manufacturing operating in OR. + +1. BACKGROUND +The customer is a manufacturing licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005151.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005151.txt new file mode 100644 index 0000000000000000000000000000000000000000..cbc0ce29a9539f93ba19af722dad105e760c624a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005151.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005151 +Opened: 2024-07-10 Investigator: INV-003 Severity: high +Customer: CUST-01553 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005152.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005152.txt new file mode 100644 index 0000000000000000000000000000000000000000..83e4ec810776bec3a66b2e26e7f8ff1753ef5ad5 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005152.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005152 +Opened: 2024-09-04 Investigator: INV-001 Severity: high +Customer: CUST-01553 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005153.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005153.txt new file mode 100644 index 0000000000000000000000000000000000000000..ae4533b1047e0bad2d01d992cd1809b687f6d2d8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005153.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005153 +Opened: 2021-04-26 Investigator: INV-003 Severity: high +Customer: CUST-01555 — testing_lab operating in MI. + +1. BACKGROUND +The customer is a testing_lab licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005154.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005154.txt new file mode 100644 index 0000000000000000000000000000000000000000..8e437f394fc953c402f0414ea7f03e446b0edb6b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005154.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005154 +Opened: 2022-06-29 Investigator: INV-004 Severity: critical +Customer: CUST-01555 — testing_lab operating in MI. + +1. BACKGROUND +The customer is a testing_lab licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005155.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005155.txt new file mode 100644 index 0000000000000000000000000000000000000000..49b8abefedd696a8a610ef77d7de47c12c95e356 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005155.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005155 +Opened: 2022-10-13 Investigator: INV-008 Severity: high +Customer: CUST-01555 — testing_lab operating in MI. + +1. BACKGROUND +The customer is a testing_lab licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005156.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005156.txt new file mode 100644 index 0000000000000000000000000000000000000000..8556b4b5c82d6b597c42fce8c39e18ed33e7841e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005156.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005156 +Opened: 2023-07-06 Investigator: INV-010 Severity: high +Customer: CUST-01555 — testing_lab operating in MI. + +1. BACKGROUND +The customer is a testing_lab licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005157.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005157.txt new file mode 100644 index 0000000000000000000000000000000000000000..78298e22256a664983d59e63bf613064dd10037b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005157.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005157 +Opened: 2024-10-21 Investigator: INV-009 Severity: moderate +Customer: CUST-01555 — testing_lab operating in MI. + +1. BACKGROUND +The customer is a testing_lab licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005158.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005158.txt new file mode 100644 index 0000000000000000000000000000000000000000..34c11517f05d11253e5ef806772275e49ccc283d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005158.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005158 +Opened: 2024-01-19 Investigator: INV-004 Severity: high +Customer: CUST-01556 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005159.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005159.txt new file mode 100644 index 0000000000000000000000000000000000000000..16f525a99c731034928d8699f4d6c467f200c304 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005159.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005159 +Opened: 2024-02-06 Investigator: INV-004 Severity: high +Customer: CUST-01556 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005160.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005160.txt new file mode 100644 index 0000000000000000000000000000000000000000..42c02657e2a3ed62f446e594343beb4153b5755d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005160.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005160 +Opened: 2024-07-11 Investigator: INV-006 Severity: high +Customer: CUST-01556 — distribution operating in CA. + +1. BACKGROUND +The customer is a distribution licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type negative_news generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005161.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005161.txt new file mode 100644 index 0000000000000000000000000000000000000000..a1cb4a753a81522358987b04a306e75fb8ab5f11 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005161.txt @@ -0,0 +1 @@ +Case CASE-005161 opened 2020-02-10 re: customer CUST-01557 (dispensary, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005162.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005162.txt new file mode 100644 index 0000000000000000000000000000000000000000..117881af80c3389e36360c99959dd76dc31fa882 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005162.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005162 +Opened: 2022-09-02 Investigator: INV-006 Severity: high +Customer: CUST-01557 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005163.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005163.txt new file mode 100644 index 0000000000000000000000000000000000000000..dd04f378c917b0a7ff0a626ab74ead0c2adc3699 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005163.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005163 +Opened: 2023-10-03 Investigator: INV-007 Severity: high +Customer: CUST-01557 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005164.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005164.txt new file mode 100644 index 0000000000000000000000000000000000000000..58074389d17d1b11508aeba4b134e2fcfc09013e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005164.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005164 +Opened: 2021-01-04 Investigator: INV-006 Severity: critical +Customer: CUST-01558 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005165.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005165.txt new file mode 100644 index 0000000000000000000000000000000000000000..73687835fb5cf2a19ef97b59c44d4e9edc71e7a8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005165.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005165 +Opened: 2023-04-03 Investigator: INV-006 Severity: high +Customer: CUST-01558 — distribution operating in OR. + +1. BACKGROUND +The customer is a distribution licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005166.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005166.txt new file mode 100644 index 0000000000000000000000000000000000000000..660c96f432aea0e3f7220591ac42c9e85ba2661a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005166.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005166 +Opened: 2021-02-08 Investigator: INV-007 Severity: high +Customer: CUST-01559 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005167.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005167.txt new file mode 100644 index 0000000000000000000000000000000000000000..f016c4953925a5bdc952fdb9e5ddd34fb5e431e3 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005167.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005167 +Opened: 2023-10-02 Investigator: INV-006 Severity: high +Customer: CUST-01559 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005168.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005168.txt new file mode 100644 index 0000000000000000000000000000000000000000..a8585cd67a75f0755eef04befc9c269213bf82e8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005168.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005168 +Opened: 2024-08-05 Investigator: INV-010 Severity: high +Customer: CUST-01559 — dispensary operating in CO. + +1. BACKGROUND +The customer is a dispensary licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cannabis_wire_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005169.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005169.txt new file mode 100644 index 0000000000000000000000000000000000000000..c3e9c8d734d302b7f328a88b60bfce81d011848d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005169.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005169 +Opened: 2023-07-12 Investigator: INV-007 Severity: high +Customer: CUST-01560 — nursery operating in CA. + +1. BACKGROUND +The customer is a nursery licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005170.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005170.txt new file mode 100644 index 0000000000000000000000000000000000000000..3ef32d18b22580bf3abd48b232325164884cc29d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005170.txt @@ -0,0 +1 @@ +Case CASE-005170 opened 2018-05-07 re: customer CUST-01561 (cultivation, MI). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005171.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005171.txt new file mode 100644 index 0000000000000000000000000000000000000000..2a8533b09f6adc6a4256a3d0b2631e8749140d42 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005171.txt @@ -0,0 +1 @@ +Case CASE-005171 opened 2020-05-04 re: customer CUST-01561 (cultivation, MI). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-005. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005172.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005172.txt new file mode 100644 index 0000000000000000000000000000000000000000..95633e1e368f85f43aea0b3fa8b4feb154154092 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005172.txt @@ -0,0 +1 @@ +Case CASE-005172 opened 2020-07-02 re: customer CUST-01561 (cultivation, MI). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-007. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005173.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005173.txt new file mode 100644 index 0000000000000000000000000000000000000000..2e00ea124454e96b151bc7783b21f7289749d67b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005173.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005173 +Opened: 2023-07-10 Investigator: INV-003 Severity: high +Customer: CUST-01561 — cultivation operating in MI. + +1. BACKGROUND +The customer is a cultivation licensed in MI. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005174.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005174.txt new file mode 100644 index 0000000000000000000000000000000000000000..23cfffe925649bad1e2b66786e1be19801f38051 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005174.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005174 +Opened: 2023-02-14 Investigator: INV-004 Severity: high +Customer: CUST-01562 — cultivation operating in OR. + +1. BACKGROUND +The customer is a cultivation licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005175.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005175.txt new file mode 100644 index 0000000000000000000000000000000000000000..da4c19fa0b5cd018a3414f655e82b2e3995699db --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005175.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005175 +Opened: 2024-02-14 Investigator: INV-010 Severity: critical +Customer: CUST-01562 — cultivation operating in OR. + +1. BACKGROUND +The customer is a cultivation licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005176.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005176.txt new file mode 100644 index 0000000000000000000000000000000000000000..f6bc890b60a0b347195a2509cad1d56ea3470e1f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005176.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005176 +Opened: 2021-12-20 Investigator: INV-006 Severity: critical +Customer: CUST-01563 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005177.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005177.txt new file mode 100644 index 0000000000000000000000000000000000000000..aabd4338d6d6cfb78ee90b1dafe15891c47e9378 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005177.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005177 +Opened: 2022-03-07 Investigator: INV-008 Severity: high +Customer: CUST-01563 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005178.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005178.txt new file mode 100644 index 0000000000000000000000000000000000000000..10a2261cfc39471bcb3c0272f942e620eb17f162 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005178.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005178 +Opened: 2022-04-04 Investigator: INV-009 Severity: high +Customer: CUST-01563 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005179.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005179.txt new file mode 100644 index 0000000000000000000000000000000000000000..076df26a4910c1face1d919ce52ad3c460b21fc2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005179.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005179 +Opened: 2022-10-10 Investigator: INV-008 Severity: high +Customer: CUST-01563 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005180.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005180.txt new file mode 100644 index 0000000000000000000000000000000000000000..f4df9a02f4d3b48c1d524293c21d4c2987fe31c6 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005180.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005180 +Opened: 2024-01-02 Investigator: INV-007 Severity: critical +Customer: CUST-01563 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005181.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005181.txt new file mode 100644 index 0000000000000000000000000000000000000000..0824eff8c8177c93681b463710b01e71a47eca4e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005181.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005181 +Opened: 2024-02-12 Investigator: INV-001 Severity: high +Customer: CUST-01563 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005182.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005182.txt new file mode 100644 index 0000000000000000000000000000000000000000..7e75a9224e94d4c9e74a384767e113d8d1f24c46 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005182.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005182 +Opened: 2024-10-02 Investigator: INV-004 Severity: high +Customer: CUST-01563 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005183.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005183.txt new file mode 100644 index 0000000000000000000000000000000000000000..e5c26dab3406e4fd4298f8314f97460e8b75c3e2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005183.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005183 +Opened: 2024-11-04 Investigator: INV-008 Severity: high +Customer: CUST-01563 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005184.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005184.txt new file mode 100644 index 0000000000000000000000000000000000000000..07ba55711f7cd17a951239bf13b5b22e5e02315a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005184.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005184 +Opened: 2021-10-04 Investigator: INV-004 Severity: high +Customer: CUST-01565 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005185.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005185.txt new file mode 100644 index 0000000000000000000000000000000000000000..120703bb6ec0d9ef7321f8625179f46257ded114 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005185.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005185 +Opened: 2022-02-23 Investigator: INV-007 Severity: critical +Customer: CUST-01565 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005186.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005186.txt new file mode 100644 index 0000000000000000000000000000000000000000..8b677a0680bc2581a137bab7bfcc6cd5f7480cc8 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005186.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005186 +Opened: 2022-05-05 Investigator: INV-005 Severity: critical +Customer: CUST-01565 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005187.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005187.txt new file mode 100644 index 0000000000000000000000000000000000000000..9ac488b1dc0a33ea7264de1b63158bc36fb687c9 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005187.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005187 +Opened: 2022-09-08 Investigator: INV-001 Severity: critical +Customer: CUST-01565 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005188.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005188.txt new file mode 100644 index 0000000000000000000000000000000000000000..1dfc2ebf97ae494c548f0626835c352e34b6f148 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005188.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005188 +Opened: 2022-12-08 Investigator: INV-001 Severity: high +Customer: CUST-01565 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005189.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005189.txt new file mode 100644 index 0000000000000000000000000000000000000000..d7363d30aa3a3201a310f6c1d33bb8456c5b558e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005189.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005189 +Opened: 2024-11-07 Investigator: INV-007 Severity: critical +Customer: CUST-01565 — delivery operating in WA. + +1. BACKGROUND +The customer is a delivery licensed in WA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005190.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005190.txt new file mode 100644 index 0000000000000000000000000000000000000000..d9ef17466e5cc7d1ab2a8691cf896ff8aa527416 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005190.txt @@ -0,0 +1 @@ +Case CASE-005190 opened 2019-06-06 re: customer CUST-01566 (cultivation, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-004. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005191.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005191.txt new file mode 100644 index 0000000000000000000000000000000000000000..c43e382c2b7ab44096f2d6b61bc5007b4e20d30b --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005191.txt @@ -0,0 +1 @@ +Case CASE-005191 opened 2020-05-11 re: customer CUST-01566 (cultivation, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-001. Suspicious activity identified consistent with structuring. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005192.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005192.txt new file mode 100644 index 0000000000000000000000000000000000000000..24ae4e8c12ab662b073fa479b4b4d173b462f26e --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005192.txt @@ -0,0 +1 @@ +Case CASE-005192 opened 2020-07-07 re: customer CUST-01566 (cultivation, CA). Alert type: structuring. 1 alert(s) reviewed. Risk tier at open: prohibited. Investigator: INV-003. No actionable suspicious activity confirmed. Case closed. Severity: high. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005193.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005193.txt new file mode 100644 index 0000000000000000000000000000000000000000..a8049ee4b71f6f0b321c38fa79aeea19e596badf --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005193.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005193 +Opened: 2021-12-07 Investigator: INV-006 Severity: high +Customer: CUST-01566 — cultivation operating in CA. + +1. BACKGROUND +The customer is a cultivation licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005194.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005194.txt new file mode 100644 index 0000000000000000000000000000000000000000..e48a8c28e3a54ae98d960fd407c54c9c2f550a0f --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005194.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005194 +Opened: 2023-07-26 Investigator: INV-010 Severity: high +Customer: CUST-01567 — manufacturing operating in CA. + +1. BACKGROUND +The customer is a manufacturing licensed in CA. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005195.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005195.txt new file mode 100644 index 0000000000000000000000000000000000000000..3fa12be0516857f0488d3001674d89f41ec9b5cf --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005195.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005195 +Opened: 2023-01-09 Investigator: INV-004 Severity: critical +Customer: CUST-01568 — dispensary operating in WA. + +1. BACKGROUND +The customer is a dispensary licensed in WA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005196.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005196.txt new file mode 100644 index 0000000000000000000000000000000000000000..276bb3e555d1310ce4e51392ac26edda74d29c9a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005196.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005196 +Opened: 2023-08-14 Investigator: INV-003 Severity: high +Customer: CUST-01568 — dispensary operating in WA. + +1. BACKGROUND +The customer is a dispensary licensed in WA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005197.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005197.txt new file mode 100644 index 0000000000000000000000000000000000000000..ef597ecd9c3eee905d6c76ed6db7a8f4b21dd49c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005197.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005197 +Opened: 2024-04-09 Investigator: INV-006 Severity: high +Customer: CUST-01568 — dispensary operating in WA. + +1. BACKGROUND +The customer is a dispensary licensed in WA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type nighttime_activity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005198.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005198.txt new file mode 100644 index 0000000000000000000000000000000000000000..0a1b12cc0fecf48399e40361c4cc67254db97048 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005198.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005198 +Opened: 2024-09-03 Investigator: INV-004 Severity: high +Customer: CUST-01568 — dispensary operating in WA. + +1. BACKGROUND +The customer is a dispensary licensed in WA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type pep_monitor generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005199.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005199.txt new file mode 100644 index 0000000000000000000000000000000000000000..aa25e75eb55424431ad7aa049d931eda4b833f5a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005199.txt @@ -0,0 +1 @@ +Case CASE-005199 opened 2020-08-27 re: customer CUST-01570 (manufacturing, CO). Alert type: cash_threshold. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-006. Suspicious activity identified consistent with cash_threshold. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005200.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005200.txt new file mode 100644 index 0000000000000000000000000000000000000000..89959bdbb78745622da846e7dbdfffce947b146a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005200.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005200 +Opened: 2021-05-12 Investigator: INV-002 Severity: critical +Customer: CUST-01570 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005201.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005201.txt new file mode 100644 index 0000000000000000000000000000000000000000..d8394110978c75bb2d3e72d371269602f5a406a1 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005201.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005201 +Opened: 2021-10-05 Investigator: INV-005 Severity: high +Customer: CUST-01570 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005202.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005202.txt new file mode 100644 index 0000000000000000000000000000000000000000..87d7c1121ebf006f5f7abeffdf17f7cf6143bd4c --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005202.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005202 +Opened: 2022-03-21 Investigator: INV-007 Severity: critical +Customer: CUST-01570 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005203.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005203.txt new file mode 100644 index 0000000000000000000000000000000000000000..30ab7f6a14f235e2d291d9ecb2eb9b2ca2c32305 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005203.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005203 +Opened: 2022-04-11 Investigator: INV-007 Severity: high +Customer: CUST-01570 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type high_risk_jurisdiction generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005204.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005204.txt new file mode 100644 index 0000000000000000000000000000000000000000..afe6abbc03eb802f8ff72cb222ac713e75d93d60 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005204.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005204 +Opened: 2023-05-02 Investigator: INV-009 Severity: high +Customer: CUST-01570 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005205.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005205.txt new file mode 100644 index 0000000000000000000000000000000000000000..e1a4df9ee0b055512f3ad4b450a4386727716c06 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005205.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005205 +Opened: 2023-09-20 Investigator: INV-005 Severity: high +Customer: CUST-01570 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 2 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005206.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005206.txt new file mode 100644 index 0000000000000000000000000000000000000000..1f1cb1e145e79d810c27c19359b2dfdefe967329 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005206.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005206 +Opened: 2023-10-19 Investigator: INV-004 Severity: high +Customer: CUST-01570 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005207.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005207.txt new file mode 100644 index 0000000000000000000000000000000000000000..3e7cb3495bb83b5a64e8b5fadd1b967f17bae275 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005207.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005207 +Opened: 2024-09-23 Investigator: INV-007 Severity: high +Customer: CUST-01570 — manufacturing operating in CO. + +1. BACKGROUND +The customer is a manufacturing licensed in CO. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005208.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005208.txt new file mode 100644 index 0000000000000000000000000000000000000000..eb25e2c2a62478cffd7d2ce1c1df797b4ffc7886 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005208.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005208 +Opened: 2024-02-14 Investigator: INV-007 Severity: high +Customer: CUST-01571 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005209.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005209.txt new file mode 100644 index 0000000000000000000000000000000000000000..d01268d719259a4eccdd0add9dcb59e446cf962a --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005209.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005209 +Opened: 2024-10-07 Investigator: INV-004 Severity: critical +Customer: CUST-01571 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type velocity generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005210.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005210.txt new file mode 100644 index 0000000000000000000000000000000000000000..a927a7eba06da4bd5775295822dec4de32e927bb --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005210.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005210 +Opened: 2024-11-11 Investigator: INV-003 Severity: high +Customer: CUST-01571 — dispensary operating in CA. + +1. BACKGROUND +The customer is a dispensary licensed in CA. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_deposit_frequency generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005211.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005211.txt new file mode 100644 index 0000000000000000000000000000000000000000..1a52f136f4a8100c3326163ae80eaeb81aeefa46 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005211.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005211 +Opened: 2021-08-23 Investigator: INV-004 Severity: high +Customer: CUST-01572 — event_organizer operating in NV. + +1. BACKGROUND +The customer is a event_organizer licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type structuring generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005212.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005212.txt new file mode 100644 index 0000000000000000000000000000000000000000..7c76ec30c3d8bab049b6e515817ba1d8e3bb9f74 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005212.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005212 +Opened: 2021-11-29 Investigator: INV-007 Severity: high +Customer: CUST-01572 — event_organizer operating in NV. + +1. BACKGROUND +The customer is a event_organizer licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005213.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005213.txt new file mode 100644 index 0000000000000000000000000000000000000000..e8faf56da452350fa1ea5e4df1f585bc6da211e5 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005213.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005213 +Opened: 2022-01-07 Investigator: INV-008 Severity: critical +Customer: CUST-01572 — event_organizer operating in NV. + +1. BACKGROUND +The customer is a event_organizer licensed in NV. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005214.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005214.txt new file mode 100644 index 0000000000000000000000000000000000000000..c38210ca6e3f83c206d53a6ccf62424cf318fa89 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005214.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005214 +Opened: 2022-10-27 Investigator: INV-007 Severity: high +Customer: CUST-01573 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005215.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005215.txt new file mode 100644 index 0000000000000000000000000000000000000000..3c04472c53fccdc5528b99dae2b8ffc221b0862d --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005215.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005215 +Opened: 2023-03-03 Investigator: INV-007 Severity: high +Customer: CUST-01573 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005216.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005216.txt new file mode 100644 index 0000000000000000000000000000000000000000..023e49623c664c8c70e1bffca198b71669250063 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005216.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005216 +Opened: 2024-08-07 Investigator: INV-010 Severity: critical +Customer: CUST-01573 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005217.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005217.txt new file mode 100644 index 0000000000000000000000000000000000000000..9331d73c4aaf7ec72f965f88f7268333990c5cca --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005217.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005217 +Opened: 2024-10-11 Investigator: INV-001 Severity: high +Customer: CUST-01573 — dispensary operating in OR. + +1. BACKGROUND +The customer is a dispensary licensed in OR. At case open the point-in-time risk tier was prohibited, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_intensity_spike generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005218.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005218.txt new file mode 100644 index 0000000000000000000000000000000000000000..3dc221fdbe2c8d6fd4b3699c9a1d445acde93a71 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005218.txt @@ -0,0 +1 @@ +Case CASE-005218 opened 2020-11-23 re: customer CUST-01574 (transport, OR). Alert type: velocity. 1 alert(s) reviewed. Risk tier at open: high. Investigator: INV-003. Suspicious activity identified consistent with velocity. SAR filed. Severity: critical. [REDACTED] account activity reviewed. Documentation retained per BSA recordkeeping requirements. \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005219.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005219.txt new file mode 100644 index 0000000000000000000000000000000000000000..21d4caf491f1cd909ac7f6aaaae0aac9cf054fc2 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005219.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005219 +Opened: 2021-05-06 Investigator: INV-003 Severity: critical +Customer: CUST-01574 — transport operating in OR. + +1. BACKGROUND +The customer is a transport licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cross_state_transfer generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion of money laundering / suspicious activity reached the moderate threshold. A Suspicious Activity Report has been filed with FinCEN per 31 CFR 1020.320. Filing made within regulatory timeframe from initial detection. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file diff --git a/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005220.txt b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005220.txt new file mode 100644 index 0000000000000000000000000000000000000000..c8b5c3e8740707f6a5d4acdfe3f14a6e960bae28 --- /dev/null +++ b/dataworld-p000384-consequence-1/environment/data/aml/case_narratives/shard-05/CASE-005220.txt @@ -0,0 +1,18 @@ +INVESTIGATION NARRATIVE — CASE-005220 +Opened: 2021-06-28 Investigator: INV-004 Severity: high +Customer: CUST-01574 — transport operating in OR. + +1. BACKGROUND +The customer is a transport licensed in OR. At case open the point-in-time risk tier was high, reflecting the institution's CRB risk-rating model. This case consolidates 1 alert(s) of type cash_threshold generated by the AML monitoring engine. + +2. ALERT REVIEW +The triggering alert(s) flagged deviation from the customer's established transaction baseline. Reviewed settlement-level transaction data, counterparty patterns, and geographic indicators. Cross-referenced against the customer's KYC profile including beneficial-ownership structure and source-of-funds documentation. + +3. ANALYSIS +The activity pattern is consistent with potential structuring and/or layering behaviour. Transaction amounts cluster near reporting thresholds; velocity exceeds the customer's 12-month baseline. [REDACTED] specific counterparties reviewed for round-tripping indicators. + +4. DETERMINATION +Suspicion did not meet the filing threshold. Case closed with no further action. Monitoring continues; the customer remains on the standard review cycle. + +5. RECORDKEEPING +Supporting documentation, transaction extracts, and analyst notes retained in the case management system per BSA/AML recordkeeping requirements (5-year retention). \ No newline at end of file