CLIENT: Halyard Money🇺🇸United States

Plumbline - AML Transaction Monitoring with Alerts, Cases and SAR Deadlines in One System

AML Monitoring Platform for a US Neobank

Designed and built a clickable AML transaction monitoring system for a US neobank and its sponsor bank: scenario alerts ranked by a transparent priority score, an investigation workspace that shows why each alert fired, real-time payment holds, and cases that count down to the SAR filing deadline.

Scope of Work
Product design, UI build and clickable demo
Industry
RegTech / AML Transaction Monitoring
FinTechEnterprise
Compliance & Certifications
Bank Secrecy ActFinCEN SAR and CTR rulesSAR confidentiality (31 U.S.C. 5318(g)(2))Anti-structuring (31 U.S.C. 5324)FinCEN CDD RuleFFIEC BSA/AML Examination ManualInteragency third-party risk guidance (2023)SR 26-2 / OCC Bulletin 2026-13

Most of our work is under NDA. Per agreement, we can share the work but not the company details - all names and identifying information shown here have been changed.

Impact

5 Screens
Clickable end to end

Dashboard, alert queue, alert investigation, cases and case detail. Every demo alert and case opens its own workspace, with close, escalate, hold and decision modals.

10 Scenarios
Core library encoded

Rapid movement of funds, two structuring rules, high-risk geographies, dormancy, P2P velocity, mule fan-in, shared devices, profile mismatch and funnel accounts, each shown with the values that crossed its threshold.

30 / 60 Days
SAR deadline on every case

Counted from the detection date, or 60 days when no suspect is identified, and red within 5 days. Alerts carry their own SLA clock of 2, 5, 10 or 15 business days by priority band.

24 Alerts
Realistic demo data

24 alerts across all 10 scenarios, 13 cases from alerts and referrals, 18 members including 2 businesses, and 9 staff users from L1 analyst to BSA/AML officer.

The Problem

Halyard Money grew from 200,000 to 1.2 million members in two years while its monitoring stayed a set of morning SQL queries exported to spreadsheets and worked in a shared inbox. Alerts sat for weeks, 97% were closed as false positives, nobody could show why a threshold was set where it was, and SAR narratives were written from scratch and emailed to the bank. The sponsor bank's oversight review found a backlog of more than 4,000 alerts and asked for a remediation plan.

Our Solution

Plumbline is that plan: one system where every alert has an owner and a clock. Scenarios raise alerts in real time and in nightly batches, analysts work them in priority order with the reason each one fired, investigators group them into cases and build the transaction story, and every case counts down to its SAR deadline under a confidentiality banner.

The Challenge: Monitoring for a Bank Without Being One

Halyard does not hold a bank charter. Its accounts and cards are issued by Prairie Ridge National Bank, an OCC-supervised sponsor bank, under an agreement that makes Halyard run day-to-day monitoring while the bank keeps ultimate responsibility for its Bank Secrecy Act program.

Deadlines Set by Regulation

A SAR is generally due within 30 calendar days of initial detection, or up to 60 when no suspect has been identified. Cash over USD 10,000 in one business day goes on a CTR within 15 days. With alerts sitting for weeks, those clocks were running before anyone looked.

Thresholds Nobody Could Defend

Supervisors expect monitoring scenarios to be governed like models, with documented design, tuning evidence and independent validation. Halyard's thresholds had no recorded rationale, and 97% of alerts led nowhere.

SAR Data That Must Not Leak

Under 31 U.S.C. 5318(g)(2), nobody involved may learn that a SAR was considered or filed. SAR data has to stay with named roles, and anything sent to member support, such as a request for information, has to use neutral wording.

Many Rails, One Customer Picture

Card, ACH, RTP, FedNow, in-app P2P and retail cash loads all arrive on different rails, some in real time. An analyst has to read them together against what the member declared at onboarding to tell a mule account from a busy hair stylist.

Our Approach: From BSA Rules to a Clickable Monitoring System

01

Spec and Rules Research

Mapped 10 roles across Halyard, the sponsor bank, validators and internal audit, 32 screens including a sponsor bank portal, and the data model for members, transactions, versioned scenarios, alerts, cases, SARs, CTRs, tuning tests, change requests and validation packs. Wrote down the rules the design follows: the BSA and FinCEN regulations, SAR and CTR timing, SAR confidentiality, structuring, the CDD rule, the 2023 third-party guidance and the April 2026 model risk guidance.

02

Clickable Demo on a Production UI Kit

Built 5 key screens on a production dashboard kit: the dashboard with KPIs, backlog by age and priority band, alert volume by scenario family and scenario effectiveness, the alert queue with Pick next and hold countdowns, the alert investigation with transactions, profile vs actual, counterparties, prior alerts and notes, the case list with SAR deadlines, and the case detail with subjects, checklist, transaction tagging and decision. All actions run on local state.

03

What a Production Build Adds

Real-time transaction streaming through Kafka, the ledger, card processor, payment rails and retail cash network, CDD profiles from onboarding, sanctions hits from screening, device intelligence and a warehouse for batch scenarios. Then the SAR editor with its narrative assistant, CTRs, scenario tuning with above- and below-the-line testing, change control, validation packs, QA sampling, the sponsor bank portal, role-based SAR clearance and a tamper-evident audit log.

Why It Works: Every Alert Has an Owner and a Clock

Alerts Explain Why They Fired

Each alert states its rule in plain language with the values that crossed it, such as inbound USD 18,400 from 11 senders in 72 hours with 94% sent out against an 80% threshold, so an analyst starts from the evidence instead of a score.

A Priority Score You Can Read

The 0 to 100 score is broken into scenario weight, customer risk rating, amount band, prior SARs, network links and account age, with bands at 80, 60 and 40. Pick next hands the analyst the highest-priority unassigned alert.

Holds and Deadlines Stay Visible

A real-time hold on an outbound payment shows its countdown in the queue and as a banner on the alert, with a release or keep decision. Cases sort by SAR deadline, and closing an alert needs a reason code and a written rationale.

Confidential by Design

Once a case has a SAR decision it carries a confidential banner citing 31 U.S.C. 5318(g)(2). Requests to member support go out as neutral tasks, and recommended account actions are carried out by operations with neutral wording to the member.

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