Case management
Also called investigation management, financial crime case management
Case management is the process and system that financial crime teams use to investigate escalated alerts. It gathers evidence, links related alerts and accounts, records each analyst's work and decision, and produces reports such as suspicious activity reports. It also keeps the audit trail that regulators and auditors review.
How it works
When an alert is escalated, the system opens a case and pulls in customer data, transactions, screening hits and past cases. Investigators add notes, request information from the business and attach documents. A reviewer approves the outcome, which may be closure, an exit, or a report to the financial intelligence unit. Deadlines and assignments are tracked in the same place.
Good case management keeps decisions consistent and defensible. It lets the MLRO see workloads, ageing cases and filing deadlines across teams. Records must be retained, typically for five years under UK, EU and US rules. Firms increasingly use AI tools to draft case summaries and narratives, with investigators reviewing and owning the final decision.
The rules
Requires banks to keep each SAR and its supporting documentation for five years from the date of filing.
Banks subject to the Bank Secrecy ActRequires firms to keep due diligence records and supporting transaction records for five years after the relationship or transaction ends.
Firms in the UK regulated sectorSaid a concise statement is generally enough where firms choose to document a decision not to file a SAR.
Banks and other SAR filersCommon questions
What is the difference between alert triage and case management?
Triage is the quick first review that closes or escalates alerts. Case management covers the deeper investigation of escalated alerts, through to a decision and any report.
What should a case file contain?
Typically the triggering alerts, customer and transaction data, evidence gathered, analyst notes, reviewer approval and the final decision with reasons. Supervisors expect files to show why each decision was made.
How long must case records be kept?
Generally five years. US rules require SARs and supporting documents to be kept for five years from filing. UK rules set five years from the end of the relationship or transaction.
Can AI write case narratives?
Firms use generative AI to draft summaries and SAR narratives. The investigator remains accountable, so drafts are reviewed and edited before a decision is recorded.
