AUSTRAC / RBNZ AML reporting pipeline
|
|
| ID |
MOD-037 |
| System |
SD06 |
| Repo |
bank-risk-platform |
| Build status |
Not started |
| Deployed |
No |
Collates SAR/STR submissions, IFTI/CMIR reports, and annual AML compliance data. Formats and submits automatically.
Approval gate (FR-807)
This module does not submit automatically. The submission orchestrator checks REGULATORY.RETURN_APPROVALS before posting to AUSTRAC or RBNZ. If no approval record exists for the current (run_id, return_code), the orchestrator aborts and alerts the Compliance team. The approval is written by MOD-170 (Regulatory Submissions Portal) — a Compliance officer reviews the assembled report in the portal Streamlit and clicks Approve. No code path in this module can bypass the gate.
Module dependencies
Depends on
| Module |
Title |
Required? |
Contract |
Reason |
| MOD-042 |
CDC pipeline — Neon logical replication to S3 Iceberg |
Required |
— |
AML alert, case, and regulatory submission data from SD03 bank_aml reaches Snowflake via the CDC pipeline. MOD-042 must have replicated raw_cdc_aml.* before this module can assemble reports. |
| MOD-018 |
Alert case management system |
Required |
— |
MOD-018 (alert case management) produces the SAR/STR source records in bank_aml Neon, which are then available in Snowflake via CDC (raw_cdc_aml schema) for report assembly. |
| MOD-019 |
Regulatory report submission module |
Required |
— |
MOD-019 (regulatory report submission) produces IFTI/CMIR submission records in bank_aml Neon, available via CDC (raw_cdc_aml schema). |
| MOD-104 |
AWS shared infrastructure bootstrap |
Required |
— |
MOD-104 provisions the S3 Iceberg bucket (Snowflake external tables), KMS key, and bank-risk-platform EventBridge bus ARN. Required before this module can be deployed. |
| MOD-102 |
Snowflake account configuration & governance |
Required |
— |
Snowflake account and governance provisioned by MOD-102 must exist before this module can read or write Snowflake. |
| MOD-170 |
Regulatory Submissions Portal |
Required |
— |
Regulatory Submissions Portal owns the approval workflow and writes to REGULATORY.RETURN_APPROVALS; the submission orchestrator in this module gates on that table — MOD-170 must be deployed for any report to progress from VALIDATED to SUBMITTED. |
Required by
| Module |
Title |
As |
Contract |
| MOD-149 |
Scam intelligence reporting & reimbursement |
Hard dependency |
— |
| MOD-170 |
Regulatory Submissions Portal |
Optional enhancement |
— |
Policies satisfied
| Policy |
Title |
Mode |
How |
| REP-003 |
AML Compliance Reporting Policy |
AUTO |
AML reporting obligations discharged automatically — no manual submission process |
| AML-001 |
AML/CFT Programme Policy |
AUTO |
Annual AML compliance report data sourced from operational systems — no manual collation |
| AML-006 |
Suspicious Activity Reporting Policy |
LOG |
SAR submissions tracked from creation to acknowledgement — no submission gaps possible |
| REP-005 |
Data Quality & Assurance Policy |
GATE |
Submission is gated by Finance officer approval in REGULATORY.RETURN_APPROVALS (via MOD-170); the submission orchestrator aborts if no approval record exists for the current (run_id, return_code) before posting to AUSTRAC or RBNZ. |
Capabilities satisfied
| Capability |
Title |
Mode |
How |
| CAP-027 |
Automated AML submission pipeline |
AUTO |
Assembles and submits AML regulatory reports (STRs, TTRs) to the relevant regulator without manual data entry. |
Part of SD06 — Snowflake Analytics & Risk Platform
Compiled 2026-05-22 from source/entities/modules/MOD-037.yaml