When a systemic failure occurs in an AML control framework, an organization may be required to run a Lookback Project. These forensic reviews analyze past transactions to identify, investigate, and report historical suspicious activity missed by the failed systems.
Activating and Executing a Lookback Project
[Trigger: Regulator Notice] ---> [Set Scope: Dates & Rules]
                                        |
                                        v
[Report: File Backdated SARs] <--- [Process: Re-Screen Transactions]

Lookback projects follow a structured process to address historical compliance gaps:
  1. Lookback Triggers: Projects are typically launched following an internal audit finding, a whistleblower tip exposing broken monitoring logic, or an explicit enforcement order from regulatory authorities.
  2. Setting the Scope: The compliance team defines clear boundaries for the review. This includes setting specific historical date ranges, identifying vulnerable product lines, and targeting affected customer segments.
  3. Re-Screening and Backdated Filings: Historical transactions are processed through corrected monitoring systems. Any newly flagged suspicious activity is fully investigated, and backdated SARs are submitted to FinCEN or FIUs to address the historical reporting gaps.

 
PreviousNext