Algorithmic Compliance and Regulatory Loss in Digital Assets

Anti-money laundering (AML) transaction monitoring generates large volumes of alerts that must be rapidly triaged by investigators under strict audit and governance constraints. While large language models (LLMs) can summarize heterogeneous evidence and draft rationales, unconstrained generation is risky in regulated workflows due to hallucinations, weak provenance, and explanations that are not faithful to the underlying decision. We propose an explainable AML triage framework that treats triage as an evidence-constrained decision process. Our method combines (i) retrieval-augmented evidence bundling from policy/typology guidance, customer context, alert triggers, and transaction subgraphs, (ii) a structured LLM output contract that requires explicit citations and separates supporting from contradicting or missing evidence, and (iii) counterfactual checks that validate whether minimal, plausible perturbations lead to coherent changes in both the triage recommendation and its rationale. We evaluate on public synthetic AML benchmarks and simulators and compare against rules, tabular and graph machine-learning baselines, and LLM-only/RAG-only variants. Results show that evidence grounding substantially improves auditability and reduces numerical and policy hallucination errors, while counterfactual validation further increases decision-linked explainability and robustness, yielding the best overall triage performance (PR-AUC 0.75; Escalate F1 0.62) and strong provenance and faithfulness metrics (citation validity 0.98; evidence support 0.88; counterfactual faithfulness 0.76). These findings indicate that governed, verifiable LLM systems can provide practical decision support for AML triage without sacrificing compliance requirements for traceability and defensibility.

Graph-based anti-money laundering (AML) systems on blockchain networks can score suspicious activity at two granularity levels -- transactions or actor addresses -- yet compliance action is conducted per actor. This paper contributes an evaluation methodology for measuring how scoring granularity affects investigation queue composition under fixed review budgets. We formalize the evaluation through a projection framework mapping transaction-level scores to the actor-level action unit via four aggregation operators, and introduce budgeted investigation metrics -- yield@budget, burden decomposition, and case fragmentation. Using the public Elliptic++ Bitcoin dataset (203,769 transactions; 822,942 address occurrences), we train independent random forest classifiers at each level under a causal temporal protocol and compare review queues through Jaccard overlap, burden decomposition, and feature-matching ablations. At one-percent budget, temporal evaluation yields mean Jaccard of 0.374 (SD 0.171); static pooled evaluation yields 0.087 (95% CI [0.079, 0.094]). An enriched address model receiving all 237 features produces even lower overlap (Jaccard=0.051), with 4.3% illicit per 100 reviews versus 30.2% for the transaction-projected queue. Address-level detection value is temporally concentrated: two timesteps exceed 91% illicit per 100 reviews while the static burden is only 3.4%. A fixed hybrid policy underperforms the best single-level queue by 5.05pp (CI [-10.2pp, -0.9pp]). These findings establish that scoring granularity is a consequential design variable for AML investigation systems -- same data, same budget, different queues, different addresses investigated.

Regulation (EU) 2024/886 obliges European payment service providers to settle euro credit transfers in under ten seconds, around the clock. This removes both the overnight batch window in which anti-money-laundering (AML) analytics traditionally ran and the settlement delay that made recovery possible, forcing detection, explanation and decision inside a single-digit-second envelope. We present KONTOGRAPH, an end-to-end AML pipeline for the SEPA Instant rail built under a self-imposed 200 ms 99th-percentile budget, and report an empirical study on 1,562,860 simulated payments with injected typologies and deliberately incomplete labels. Three findings are of interest beyond the system itself. First, a temporal graph network with per-node memory improves PR-AUC over a gradient-boosted tabular baseline from 0.0053 to 0.1717, a paired day-blocked bootstrap difference of +0.166 with 95% CI [0.105, 0.241]; per-node memory alone more than doubles the score. Second, expressing each feature once and compiling it to three execution backends, with equivalence enforced by property-based tests that perturb the future, surfaced three point-in-time violations that code review had passed--each of which would have inflated reported performance. Third, and most consequential for practice, exporting the deployed tree ensemble to ONNX changed only $7.4 \times 10^{-8}$ in mean score yet altered 0.26% of decisions and inflated the alert volume by 12%, because 32-bit accumulation perturbs scores across a cost-optimal threshold of $3.98 \times 10^{-4}$. We argue that a serving-format conversion must be treated as a model change until measured, and that fidelity metrics for subgraph explainers can be vacuous when candidate neighbourhoods are small--a null result we report in full.