Segments
Parse alert and load policy
3sRule TM-GEO-002 resolved to typology "PEP exposure". Loaded the US policy pack and the institution's escalation matrix.
Intake · 1 records
Retrieve KYC and relationship history
11sPulled the customer file, prior dispositions and the current risk rating.
KYC retrieval · 14 records
Reconstruct transaction history
27sAnalysed 3 alerted transactions against a trailing twelve-month baseline; tested for threshold proximity, velocity, round-value patterning and pass-through.
Transaction analysis · 343 records
Expand counterparty network to 1 hop
34sResolved 2 counterparties and tested for shared identifiers, device overlap, circular flow and undisclosed common control.
Counterparty network · 25 records
Screen subject and counterparties
19sScreened against consolidated sanctions lists, the global PEP register and internal watchlists; applied the institution's discriminator rules to each candidate.
Sanctions & PEP · 4 records
Adverse media sweep
22sSearched 42 languages across licensed and open sources, deduplicated by event and tested each candidate for homonym risk.
Adverse media · 1,840 records
Weigh evidence and reach disposition
16sAggregated 7 weighted findings; suspicion score 0.29 against the institution's thresholds.
Risk reasoning · 7 records
Draft regulator-grade narrative
14sComposed the six-part narrative with a source citation on every asserted fact.
Narrative drafting · 7 records
Self-check against the QA rubric
9sVerified every narrative assertion resolves to a retrieved record, checked policy citations and tested the disposition against the escalation matrix.
Self-QA · 7 records
Activity materially exceeds declared expectation
Alerted volume 62,500 USD against a declared monthly expectation of 25,000 USD (2.5×).
KYC profile CUS-330871
Confirmed PEP/RCA match
Restrepo Vélez, A. — relative of a former departmental assembly member (CO) — Confirmed RCA (relative or close associate) of a former sub-national official who left office in 2018. Classified low-tier under the institution's PEP policy; EDD refreshed and source of wealth evidenced.
Global PEP register — RCA
Transactions carry a consistent, verifiable economic purpose
3 of 3 transactions reference an identifiable instrument — Property sale settlement; Payroll.
Payment reference fields
Counterparties corroborated by documentation already on file
2 counterparties are evidenced in the customer file: Escrow reference matches the deed supplied at onboarding review; Declared employer.
Customer document store
Screening alert discounted on identified discriminators
Restrepo (fuzzy, 0.71) discounted: DOB differs by 14 years; Listed entity resident in a different jurisdiction; No shared identifiers.
OFAC SDN + Consolidated, UN, EU, UK OFSI
Established relationship with a stable alerting history
7-year relationship with 1 alert in the trailing twelve months, all previously dispositioned without a filing.
Case management history
Counterparty risk flags reviewed and attributable
Flags on 1 counterparty resolve to cross-border or sector attributes already captured in the customer's risk rating.
Counterparty register
Subject
Ana Sofía Restrepo Vélez (CUS-330871) is an individual customer of the institution since September 3, 2019, resident in Miami, Florida, US and recorded as regional director, medical devices distributor. The relationship carries a medium inherent risk rating, last reviewed January 20, 2026. Declared source of funds is salary, property sale proceeds, with an expected monthly throughput of 25,000 USD. Identity was verified on September 3, 2019 by documentary + biometric.
Activity under review
Alert ALT-2026-88063 was generated by rule TM-GEO-002 — inbound wire from jurisdiction on the enhanced-monitoring list — covering 3 transactions totalling 62,500 USD through the wires channel between July 12, 2026 to August 28, 2026. 3 inbound and 0 outbound movements were reviewed in full, together with the customer's trailing twelve-month history and 2 counterparties resolved to 1 hop.
Findings
(1) Activity materially exceeds declared expectation. Alerted volume 62,500 USD against a declared monthly expectation of 25,000 USD (2.5×). [KYC profile CUS-330871] (2) Confirmed PEP/RCA match. Restrepo Vélez, A. — relative of a former departmental assembly member (CO) — Confirmed RCA (relative or close associate) of a former sub-national official who left office in 2018. Classified low-tier under the institution's PEP policy; EDD refreshed and source of wealth evidenced. [Global PEP register — RCA]
Mitigating evidence
(1) Transactions carry a consistent, verifiable economic purpose. 3 of 3 transactions reference an identifiable instrument — Property sale settlement; Payroll. [Payment reference fields] (2) Counterparties corroborated by documentation already on file. 2 counterparties are evidenced in the customer file: Escrow reference matches the deed supplied at onboarding review; Declared employer. [Customer document store] (3) Screening alert discounted on identified discriminators. Restrepo (fuzzy, 0.71) discounted: DOB differs by 14 years; Listed entity resident in a different jurisdiction; No shared identifiers. [OFAC SDN + Consolidated, UN, EU, UK OFSI] (4) Established relationship with a stable alerting history. 7-year relationship with 1 alert in the trailing twelve months, all previously dispositioned without a filing. [Case management history] (5) Counterparty risk flags reviewed and attributable. Flags on 1 counterparty resolve to cross-border or sector attributes already captured in the customer's risk rating. [Counterparty register]
Screening
Global PEP register — RCA: Restrepo Vélez, A. — relative of a former departmental assembly member (CO) (score 0.91) — confirmed. Confirmed RCA (relative or close associate) of a former sub-national official who left office in 2018. Classified low-tier under the institution's PEP policy; EDD refreshed and source of wealth evidenced. OFAC SDN + Consolidated, UN, EU, UK OFSI: Restrepo (fuzzy, 0.71) (score 0.71) — discounted. Name-only overlap on a common surname. Date of birth, nationality and all secondary identifiers diverge. Discounted under the institution's two-discriminator rule.
Disposition
The activity is explained by the customer's documented profile and no further action is recommended. The alert is closed as a false positive. This determination was produced by heelius-investigator-4.2 · policy-pack us-bsa-2026.08 with a calibrated confidence of 72% and is subject to the institution's quality-assurance sampling programme.
Source of wealth evidenced, RCA tier correctly applied. Narrative is filing-ready as drafted.
S. Lindqvist · L3