medium · FRM Part 2 Operational Risk

A bank is evaluating the use of Machine Learning (ML) to triage transaction monitoring alerts.

Which new risk-management obligation does this 'ML Triage' model create?

  1. It allows the bank to shift all AML monitoring responsibilities entirely from the first line onto the IT department.
  2. The bank must validate the 'explainability' of suppressed alerts to prove that the model is not creating invisible false negatives.
  3. The ML model must be trained exclusively on external loss data sourced from competitor institutions rather than internal history.
  4. It removes the bank's need to file Suspicious Activity Reports (SARs), since the ML triage model now assumes that regulatory reporting duty.

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