medium · Frm Part 2 Current Issues

A bank discovers that its transaction monitoring system for Anti-Money Laundering (AML) has a 99% false positive rate. As part of a risk-based approach, the bank implements a Machine Learning triage model.

What is the bank's primary ongoing obligation to regulators regarding this new model?

  1. To outsource the model's operation to a third-party vendor to eliminate accountability for errors.
  2. To provide 'explainability' for why specific alerts were suppressed and perform regular 'backtesting' of suppressed alerts.
  3. To ensure the model only uses three input features to maintain simplicity.
  4. To prove that the model has zero false negatives (i.e., it catches 100% of all laundering).

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