BPO Service
AML outsourcing for alert review and backlog clearance
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You can outsource defined AML review tasks; your institution keeps the AML program, oversight and final decisions.
Direct answer
AML outsourcing is the transfer of anti-money laundering (AML) operations, such as alert review and suspicious activity report (SAR) drafting, to an external team. Actigy BPO provides AML outsourcing: transaction monitoring alert review, sanctions and PEP screening, case files and SAR drafting support. The team delivers from Bulgaria, Romania, Poland and Ukraine. Your money laundering reporting officer (MLRO) keeps the AML program and every filing decision. Pricing is per FTE by role, and every engagement starts with a paid pilot.
Bring an alert sample, monthly volume and a named escalation owner. Your legal and compliance team approves the scope for your jurisdiction.
Defined data-access controls · You own the SOPs · Pilot before you scale
AML results: 88% less manual false-positive triage (Actigy BPO-reported)
- Cut manual false-positive triage by 88%.
- Processed high-risk verifications under a 15-minute SLA.
- Cleared a backlog of 14,000 pending verifications.
Results come from anonymized client engagements, are reported by Actigy BPO and are not independently audited. Results depend on scope. The 15-minute service-level agreement (SLA) applied to this engagement, not every alert queue. Fintech case: 88% less manual false-positive triage.
At a glance
AML outsourcing at a glance: scope, team and controls
| Tasks | Transaction-monitoring triage, sanctions and politically exposed person (PEP) screening review, adverse-media review, case files, SAR/STR drafting support and backlog remediation |
|---|---|
| Pricing model | Per full-time equivalent (FTE) by role; alert volume and investigation depth determine staffing |
| Team | Trained analysts, technical leadership and quality assurance (QA), named in the proposal |
| Coverage | Business hours to 24/7, agreed for the queue |
| Delivery | Bulgaria, Romania, Poland and Ukraine; confirm the actual team location |
| Controls | Approved access, documented standard operating procedures (SOPs), review separation and QA sampling |
| You keep | The AML program, risk policy, regulatory filings and final decisions |
What AML work can be outsourced, and what cannot?
Actigy BPO can run defined AML casework under your thresholds, typologies and escalation rules. The scope may include alert review, screening-hit triage, investigation support and case documentation. List permitted dispositions and stop conditions before assigning a live queue.
Your MLRO or nominated officer keeps the AML program and regulatory filing decisions. An external team does not remove the need for oversight or legal review. Actigy BPO supplies evidence and draft narratives for the authorized decision-maker; it does not assume that role.
Keep records and decision ownership clear when coordinating KYC onboarding and refresh backlogs with AML alert review.
| AML task | Outsourced team | Your institution |
|---|---|---|
| Transaction monitoring alerts | Reviews alerts, records evidence and applies only approved disposition or escalation rules | Sets thresholds, scenarios and typologies |
| Sanctions and PEP screening | Reviews hits under the approved lists, methodology and authority limits | Owns the lists and the risk methodology |
| Adverse media | Runs negative-news checks and summarizes them for escalation | Decides on escalated cases |
| Case files | Builds the investigation file and the audit trail | Reviews the file |
| SAR and STR | Drafts the narrative and the evidence pack | Decides to file and files the report |
| AML program | Runs your procedures; does not set risk appetite or act as MLRO | Owns the program and the risk appetite |
Inside the work
How does L1 alert triage work?
Level 1 (L1) triage checks an alert against your approved rules, records the evidence and routes the outcome. It does not give the team authority to change thresholds or make a regulatory filing decision.
- Confirm the queue: record alert type, age, priority and the permitted actions in the SOP.
- Gather the evidence: review the customer, transaction or screening information available in approved systems.
- Check the context: compare the alert with the applicable rule and record missing or conflicting evidence.
- Write the rationale: explain the proposed disposition or reason for escalation. Do not close a case just to reduce the backlog.
- Apply QA: use the agreed second-review rules and sample checks. Track defects and reopened cases.
- Route the outcome: close only within the approved authority limit, or send the evidence to the named client reviewer. SAR and STR decisions stay with your officer.
What is a red flag in AML review?
A red flag is an indicator to assess in context under the client's policy, not a finding of money laundering. Missing customer context, unexplained activity or conflicting screening identifiers may need further review. The case file should state the evidence, uncertainty and escalation reason; the client decides the required action.
Who offers outsourced AML alert review for small banks and credit unions?
Actigy BPO offers a managed review team for small banks, credit unions and fintechs with a defined alert queue. The team can assemble case evidence and draft a SAR or STR narrative. Your BSA or AML officer, or MLRO, keeps the filing decision and filing action. Confirm that volume, oversight and access controls justify a managed team before starting.
Delivery locations are Bulgaria, Romania, Poland and Ukraine. Name the actual team location, staffed hours and escalation coverage in the contract. Review the permissions, data-handling terms and control evidence before sharing live cases.
In an anonymized fintech engagement, Actigy BPO cut manual false-positive triage by 88% and held high-risk reviews under a 15-minute SLA (Actigy BPO-reported). The team reviewed PEP and sanctions matches with adverse-media searches. A second reviewer checked every case marked for escalation or rejection. Those are case-specific results, not a standard SLA for every alert queue.
How much does outsourced AML cost?
Actigy BPO prices AML alert review per FTE per month, by role: analyst, senior investigator and QA. Team size follows your monthly alert volume, the average handling time per alert and your escalation rate. After the pilot, the team reports the cost per closed alert, so you can compare it with per-alert quotes and with in-house cost.
The proposal identifies the analysts, technical leadership and QA needed for the queue. Agree the pilot date after checking case-tool access, policy training and the availability of your decision-makers.
| Cost area | What to include | Who sets the scope |
|---|---|---|
| Managed queue | Analysts, senior review, QA, leadership, training and the agreed coverage. | The written proposal identifies roles, included work and change terms. |
| Retained client work | Officer oversight, escalated decisions, policy approval and filing time. | Your institution retains these responsibilities and budgets for them. |
| Tools and data | Monitoring software, screening data, case systems and access setup. | Confirm what is already licensed, what is included and what is charged separately. |
| Wider AML program | Policy advice, program review and other compliance work outside the queue. | A managed-review quote is not a quote for your entire compliance program. |
Compare effective cost per closed alert only for the same investigation depth, QA and closure standard. Include rework and reopened cases consistently. There is no universal per-alert price or savings promise for a different risk mix.
AML consultant or managed service: which do you need?
Hire an AML consultant to design or fix the program: risk assessment, policy, scenarios, thresholds and model validation. Use a managed service such as Actigy BPO to run the daily work inside that program: alert triage, screening review, case files and SAR drafting. It runs your procedures and does not set your risk appetite or act as MLRO.
The two roles fit together. The consultant sets or tunes scenarios and thresholds, and the managed team works the alerts that those rules produce.
| Need | Consultant scope | Managed-team scope |
|---|---|---|
| Program design or repair | Assess the program and recommend policy, scenario or model changes. | Identify operational issues and work to the approved program. |
| Daily alert queue | Define review or remediation requirements if included in the assignment. | Review alerts, collect evidence, record rationale and route exceptions. |
| Expected output | Advice, a review or a defined design deliverable. | Completed casework, draft narratives, QA findings and queue reports. |
| Change authority | Client approval is needed before recommendations change the live policy. | No independent change to thresholds, risk appetite or filing authority. |
Your institution approves program changes and keeps the accountable officer role in either model. Confirm the consultant's actual remit; a provider label alone does not establish the services included.
What does SAR review outsourcing include?
Actigy BPO prepares SAR and suspicious transaction report (STR) drafts from the case file. Each draft covers the subject, the activity, the red flags, the timeline and the supporting evidence. A senior reviewer checks each draft before it goes to your MLRO. Filing decisions and contact with the regulator stay with your institution.
Actigy BPO never files with regulators. Each draft cites the evidence in the case file, so your MLRO can check how the team reached its recommendation.
Scenarios
When does an AML queue need extra review capacity?
Extra capacity is useful when the work is defined and client decision-makers can handle the escalations it produces. Assess new alerts and the old backlog separately.
A screening change creates a large new batch.
Confirm the approved list or rule version, priority order and closure rules before review. Keep uncertain sanctions and PEP matches visible; volume alone is not a reason to clear them.
Transaction-monitoring alerts exceed available capacity.
Separate queues by type, age and risk. Agree a backlog plan without hiding the daily arrival rate or the work awaiting client decisions.
An examiner questions case quality.
Review the evidence and rationale against the approved standard. Track defects and have the policy owner approve any changed instructions.
A new product changes the review workload.
Your policy owner sets the required controls and rules. Train the team on the approved changes before it handles the new alert types.
How should bulk sanctions alert clearing be scoped?
Scope a review batch, not blanket clearance. Record the input set, approved screening method, evidence required for a non-match and triggers for escalation. Confirm who can authorize each outcome, test a sample and report unresolved matches separately. The operations team does not relax the screening rules to meet a throughput target.
Is a managed AML team the right fit?
A defined queue and retained oversight
- Banks, credit unions, fintechs and payment firms with documented AML rules.
- An alert or case backlog that exceeds in-house capacity.
- A named officer and escalation owner for the staffed hours.
- Access to the evidence needed for review and agreed QA checks.
- A remediation or growth plan that starts with a paid pilot.
Resolve these gaps before launch
- A request for the provider to act as your MLRO or own filing decisions.
- No defined risk methodology, permitted dispositions or escalation path.
- A need for legal interpretation or a monitoring software product instead of an operations team.
- No capacity inside your institution to review escalated cases.
AML and fraud work may share an operating team only when the scope approves it. Keep separate notes, permitted actions and decision paths for each process.
What does Australian guidance say about AML outsourcing?
AUSTRAC's guidance on using outsourcing, updated July 13, 2026, says Australian reporting entities retain responsibility for their AML/CTF obligations when they outsource functions. It describes provider due diligence, written agreements and ongoing oversight.
For Australian firms reviewing Tranche 2 requirements, AUSTRAC's AML/CTF reform overview, updated September 25, 2026, links to guidance for newly regulated entities and transitional rules. Confirm applicability with your legal and compliance advisers.
This is Australian regulatory context, not permission for every task or jurisdiction. Review restrictions on sharing case information before granting access. The service described here does not include legal advice, the MLRO role or filing with a regulator.
Delivery method
How does an AML pilot test quality before scale?
Start with one alert queue and include difficult cases: a high-risk customer, a policy exception and a case needing a second-line decision. The proposal names the team, locations, staffed hours and controls. The pilot tests them on your work.
| Stage | What happens |
|---|---|
| Process audit and written scope | Agree alert types, permitted dispositions, case-note requirements, QA and escalation owners. Approve access and policy-training results before live work. |
| Paid pilot | Run one queue with the agreed second-review rules. Measure case quality, turnaround and cost per closed alert, including reopened cases. |
| Scale gate | Your officer accepts the results against the agreed thresholds before additional queues or volume are added. |
A pilot usually starts 2 to 4 weeks after the process audit. The date depends on system access, training scope and client approvals. Do not assume that a proposed start date is an alert-resolution SLA.
See the full delivery method: How a pilot works.
Visibility
What should the monthly AML report show?
Review case quality, turnaround and capacity together. A low closure cost is not useful if cases are reopened or unsupported dispositions pass QA.
- QA results, evidence gaps and recurring errors against the agreed review standard.
- Turnaround and throughput against queue-specific targets.
- New alerts, backlog age and cases awaiting client decisions.
- Cost per closed alert with consistent rework and reopening treatment.
- Root-cause findings and proposed SOP changes for the policy owner's approval.
Which controls should you inspect before granting access?
Inspect the actual permissions, logs, approved delivery locations and review separation for the proposed team. Confirm which records may be shared, exported or retained. Your institution approves data access and any later change to the scope.
- GDPR-compliant delivery: Actigy BPO agrees delivery locations and data-processing terms for each client.
- ISO 9001-aligned quality management (documented SOPs, QA sampling, root-cause reviews). Aligned, not certified.
- SOC 2-aligned controls (role-based access, logging, segregation of duties). Aligned, not audited.
You own the SOPs. Keep approved procedures and case-note standards available for oversight and handover. Agree how current documentation and open cases will return to you if the engagement ends.
Compare the cost-to-quality ratio using the same investigation depth and retained officer time. Related KYC outsourcing can be coordinated only with clear records and authority for each queue.
AML alert review for US financial-services teams
Actigy BPO fits an AML team whose monitoring and screening tools produce more review work than its staff can handle. Operators check permitted evidence, document the rationale and escalate cases under client rules. For a US engagement, the named BSA/AML officer or other authorized client owner retains program decisions and SAR filing authority.
Transaction-monitoring alerts and screening backlogs
Separate transaction alerts from sanctions, PEP and adverse-media matches. Agree the checks and escalation threshold for each queue. A low-risk disposition needs documented evidence and the required review; reducing the alert count is not a reason to close unresolved cases.
Surge capacity and case-file QA
Actigy BPO can scope review capacity for a backlog, launch or time-bounded remediation. The plan names staffing, training and end-of-project handover. Operational QA samples evidence, rationale and escalation quality. It is not an independent AML program audit or a promise that an examination will pass.
Prepare the records for a separate reviewer with the Actigy BPO AML audit checklist and evidence workpaper. It connects scope, population, test results and remediation evidence while keeping operational QA distinct from independent assurance.
US banks remain responsible for managing third-party risk. The FDIC third-party relationships guidance is a starting point for the buyer's own review. Confirm restrictions on records, offshore access and reporting with your compliance team before sharing live cases.
FAQ
Frequently asked questions
What is AML outsourcing?
AML outsourcing assigns defined financial-crime casework to an external operations team. Actigy BPO can review monitoring alerts and screening hits, assemble case files and prepare SAR drafting support under your rules. Your MLRO retains the program, accountability and filing decisions.
Can Actigy BPO file SARs on our behalf?
No. Actigy BPO prepares draft SAR/STR narratives and assembles supporting evidence. The decision to file and the filing itself remain with your nominated officer or MLRO. The goal is a faster, better-documented decision, not a transfer of their accountability.
Does Actigy BPO replace our transaction-monitoring system?
No. Actigy BPO is the operations team that works the alerts your system generates. It operates inside your monitoring, screening, and case-management tools rather than replacing them. Your data and decisioning stay in your own systems.
Can Actigy BPO clear an alert backlog?
Actigy BPO can scope backlog review by alert type, age and risk. Define which cases need client decisions and what QA evidence is required before closure. Review ongoing arrivals and handling capacity separately; backlog remediation does not guarantee that future volume will stay within the team's capacity.
How is AML casework quality controlled?
Actigy BPO trains analysts on your policy and typologies and checks readiness before live work. Agree second-review rules, QA samples and required source evidence. Review recurring errors with the policy owner rather than allowing the operations team to change thresholds itself. Internal training sign-off is not an external certification.
How much does AML outsourcing cost?
Actigy BPO uses monthly per-FTE pricing by role, not a per-alert fee. Alert volume, handling time, escalation rate, coverage and review depth affect staffing and total cost. Compare effective cost per closed alert only after agreeing the closure definition, rework treatment and included QA.
Can you outsource AML compliance operations?
Actigy BPO's offer covers operational review and drafting support, not ownership of the AML program. Before contracting, your legal and compliance team should approve the permitted tasks, data access, oversight and reporting arrangements for your jurisdiction. The client retains the MLRO role and filing authority.
Related services and industries
Services
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Resources
Actigy BPO separates alert review from KYC remediation of deficient customer files. The client retains risk and filing decisions.
Start with one AML queue and a clear decision boundary.
Bring an alert sample, monthly volume, coverage needs and a named officer. Review the proposed scope, controls and cost before approving a pilot.
Your officer accepts the pilot results before more alert volume is assigned.
Scope a pilot
What happens next
The team reviews the workflow before proposing a written scope. You decide whether to start a paid pilot after reviewing it.