Pilot Specification #1 — BSA/AML Sanctions Alert Triage

Heritage Community Credit Union
Journey deliverable · Seiche Advisors
Version: 1.0 · August 2026
Status: Board-authorized pending POC contract

1. Pilot summary

Field	Value
Use case	AI-assisted triage of OFAC/sanctions alerts before analyst review
Primary vendor (recommended)	Nasdaq Verafin — agentic sanctions review module
Duration	90 days (POC) + 30-day evaluation
Start target	November 1, 2026
Executive sponsor	Diane Foster, BSA Officer
Technical owner	James Wu, CIO
Budget (POC)	$45K–$65K (license + services)

2. Problem statement

HCCU BSA team processes ~1,400 alerts/month across sanctions screening and transaction monitoring. Internal time study (June 2026) shows:

62% of analyst time on false-positive disposition
18% on true-positive investigation
20% on SAR drafting and QA

Sanctions alerts average 47 minutes each to clear; 73% are false positives. At 4 FTE analysts, backlog risk is increasing as wire volume grows.

3. Pilot objective

Demonstrate that AI-assisted sanctions alert triage can reduce analyst time per alert by ≥40% without increasing missed true positives, measured against a 90-day baseline.

4. Scope

In scope

OFAC/sanctions alerts generated by existing Abrigo BAM+ workflow
Alert enrichment, duplicate detection, and recommended disposition (escalate / clear)
Analyst review and override of all AI recommendations (human-in-the-loop mandatory)
MRM documentation: model card, validation summary, override log

Out of scope

Full AML transaction monitoring replacement
Autonomous SAR filing
Member-facing communications
Credit decisioning

5. Success metrics

Metric	Baseline	Target (90-day)
Avg. minutes per sanctions alert	47 min	≤28 min
False positive rate (unchanged or lower)	73%	≤73%
Missed true positives	0 in baseline quarter	0
Analyst overtime hours/month	38 hrs	≤20 hrs
Override rate (AI vs. analyst)	N/A	Track; expect 15–25% initially

6. Data & integration

System	Role
Symitar	Source of member and transaction data
Abrigo BAM+	Alert origination; disposition workflow
Verafin	AI triage layer (API integration)

Data classification: Restricted — member PII, transaction data. Processing in vendor SOC 2 environment; no training on HCCU data per contract Exhibit B.

7. Governance & compliance

Human-in-the-loop: No alert closed without analyst sign-off in POC phase
Model risk: Documented in AI inventory; annual validation per SR 11-7 principles
Fair lending: N/A for BSA use case
Examiner narrative: One-page POC summary for NCUA annual exam file

8. Timeline

Week	Activity
1–2	Contract, DPA, vendor security review
3–4	Integration build, test environment
5–6	Parallel run (AI recommends, analysts decide without AI influence) — baseline
7–14	AI-assisted triage live; daily override review
15–16	Results analysis, board memo, scale/stop recommendation

9. Budget

Line item	Amount
Verafin POC license (90 days)	$28K–$38K
Implementation / integration	$12K–$18K
Seiche PMO (fractional)	$5K
Total POC	$45K–$61K

Scale decision (if successful): Full annual license $95K–$130K — included in Year 2 budget request.

10. Risks & mitigations

Risk	Mitigation
Integration delay with Symitar	Jack Henry vendor management call Week 1
Analyst resistance	Co-design workflow; Foster leads change mgmt
Vendor model update	Contract notification clause; re-validation trigger

11. Scale / stop criteria

Scale if: ≥40% time reduction, zero missed TPs, override rate stabilizes below 20% by Week 14.

Stop if: any missed true positive, examiner objection, or <20% time reduction with no improvement trend.

Approvals

Role	Signature	Date
BSA Officer
CRO
CIO
CEO