Worked case · Failure and stress · 12 figures

Institution-specific duty map

Map duties to the actual institution

Figure 01 / 12

Determine the eligible population first

Determine the eligible population first — Institution-specific duty map. Count; records. Exact values are in the figure data below.
Count; records

Of 980 source records, 823 are within the stated synthetic scope and 157 are outside it. Eligibility here is an explicit teaching input, not a legal conclusion. Production classification must use the actual entity, product, activity, jurisdiction, and facts.

Figure data and text version
Scope stateRecords
Within stated scope823
Outside stated scope157

The product uses a fintech interface, a sponsor bank, and several service providers. The applicable duty follows the entity and activity, not the product’s marketing label.

A vendor screening result is mistaken for completion of the institution’s entire program obligation.

All amounts, rates, capacity limits, and outcomes in this case are synthetic. The three conditions are separate assumptions for comparison. A better result in the response condition is not measured proof that the proposed control causes that improvement. The figures expose the calculation and its limits; a real deployment needs its own evidence.

Read the result

The case identifies 823 eligible records from a source population of 980. The required workflow completes for 642, but 83 completed records miss the illustrative internal target. Another 181 remain incomplete. Communication evidence covers 559 generated notices. Scope, completion, timeliness, and delivery are four separate properties of the customer outcome.

Model inputs and calculated values

Inputs below are the case-specific values. Each figure states the condition-specific assumptions and units used in its calculation. Calculated values are rounded for display.

InputValue
population980
eligibility0.84
Calculated valueResult
population980
eligible823
excluded157
complete642
incomplete181
late83
ontime559
notices559
undelivered83
pending61
reviewed120
Figure 02 / 12

A control can miss eligible records

A control can miss eligible records — Institution-specific duty map. Count at a fixed observation cutoff. Exact values are in the figure data below.
Count at a fixed observation cutoff

The required workflow completes for 642 of the 823 eligible records. The 181 remainder needs an owned exception path. Reporting completion as a percentage of all source records would answer a different question and could hide the actual coverage gap.

Figure data and text version
MeasureRecords
Eligible records823
Workflow completed642
Workflow incomplete181
Figure 03 / 12

Completion and timeliness are distinct outcomes

Completion and timeliness are distinct outcomes — Institution-specific duty map. Count; exclusive states within eligible population. Exact values are in the figure data below.
Count; exclusive states within eligible population

The illustration applies an internal target, not a statutory deadline. Of 642 completed records, 83 miss that target and 559 meet it. The 181 open records are a third state; do not automatically classify them as timely merely because their final outcome is unknown.

Figure data and text version
OutcomeEligible records
Complete within target559
Complete after target83
Still incomplete181
Figure 04 / 12

An obligation record connects authority to behavior

An obligation record connects authority to behavior — Institution-specific duty map. Control contract. Exact values are in the figure data below.
Control contract

This case implements map duties to the actual institution. The record separates scope, trigger, required action, ownership, and retained proof. Exact legal duties belong to the applicable source and interpretation; the timing and counts in this worked example are synthetic.

Figure data and text version
ElementIllustrative value
Control subjectInstitution-specific duty map
ScopeThe eligible population defined above
TriggerA vendor screening result is mistaken for completion of the institution’s entire program obligation.
Required behaviormap duties to the actual institution
OwnerBSA compliance owner
EvidenceVersioned event, action, and communication records
Figure 05 / 12

Different clocks start from different facts

Different clocks start from different facts — Institution-specific duty map. Internal teaching timeline; not a legal deadline schedule. Exact values are in the figure data below.
Internal teaching timeline; not a legal deadline schedule

These relative times are illustrative service targets. They deliberately distinguish customer contact, receipt by the institution, classification, investigation, and communication. A routing delay must not silently replace the original receipt time when that fact matters.

Figure data and text version
EventIllustrative timeRecord
Customer reportT0Original channel and words
Institution receiptT0 + 5 minutesRetained receipt timestamp
ClassificationT0 + 20 minutesApplicable process and owner
Internal review targetT0 + 1 dayInternal target only
Outcome communicationAt decisionContent, destination, and delivery state
Figure 06 / 12

Evidence fields fail independently

Evidence fields fail independently — Institution-specific duty map. Count; overlapping field-level checks. Exact values are in the figure data below.
Count; overlapping field-level checks

Each row is one evidence requirement over the eligible population. The same record can fail several checks, so the absent counts across rows must not be added as though they were distinct customers. Completeness does not itself prove that a field is accurate.

Figure data and text version
Evidence fieldPresentAbsent
scope75766
trigger72499
action700123
notice74182
evidence658165
Figure 07 / 12

A generated notice is not a delivered notice

A generated notice is not a delivered notice — Institution-specific duty map. Count; generated equals delivered plus unresolved. Exact values are in the figure data below.
Count; generated equals delivered plus unresolved

642 completed records generate a modeled notice event. 559 have a delivered state and 83 do not. The system must distinguish generation, dispatch, delivery evidence, and any required follow-up under the actual process.

Figure data and text version
Communication stateNotices
Generated642
Delivered state recorded559
Delivery unresolved83
Figure 08 / 12

Authority differs by operation

Authority differs by operation — Institution-specific duty map. Illustrative permission matrix. Exact values are in the figure data below.
Illustrative permission matrix

The access matrix is a proposed teaching separation of duties. Read, propose, approve, and administer are distinct capabilities. The final policy must match the organization’s actual roles and obligations, with controlled emergency access and an audit trail.

Figure data and text version
RoleRead evidencePropose actionApprove release
BSA compliance ownerScopedYesNo
Independent approverScopedNoYes
SupportLimitedRequest onlyNo
System administratorOperational logsNoNo
Figure 09 / 12

Exceptions need capacity and a closing state

Exceptions need capacity and a closing state — Institution-specific duty map. Records per observation window. Exact values are in the figure data below.
Records per observation window

The control has 181 incomplete records. The available exception capacity covers 120, leaving 61 pending. A pending state requires an owner and a next action; changing a status label without resolving the required behavior does not close the gap.

Figure data and text version
Queue itemRecordsMeaning
Exceptions opened181Eligible workflow incomplete
Capacity applied120Records handled in this window
Pending exceptions61Still require an owned response
Figure 10 / 12

A rate includes its denominator

A rate includes its denominator — Institution-specific duty map. Percent; named populations. Exact values are in the figure data below.
Percent; named populations

These rates deliberately use different populations. Overall throughput, eligible coverage, completed-record timeliness, and delivery evidence are not interchangeable. Each needs the same cohort, cutoff, and definition every time it is compared.

Figure data and text version
MetricNumeratorDenominatorPercent
Eligible coverage64282378.01
On-time among completed55964287.07
On-time among eligible55982367.92
Delivered among generated55964287.07
Figure 11 / 12

A change needs an evidence trail

A change needs an evidence trail — Institution-specific duty map. Control-change lifecycle. Exact values are in the figure data below.
Control-change lifecycle

The trigger is A vendor screening result is mistaken for completion of the institution’s entire program obligation.. A controlled change connects the revised requirement or interpretation to implementation, replay, customer impact, and approval. The old version remains relevant to decisions already made under it.

Figure data and text version
StageRetained proof
InterpretScope, source, effective date, and owner
ImplementVersioned logic, data contract, and message template
VerifyBoundary cases and affected-population comparison
ReleaseApproval, start time, and rollback condition
CorrectAffected records and customer outcome where required
Figure 12 / 12

Correction follows the affected population

Correction follows the affected population — Institution-specific duty map. Illustrative correction responsibilities. Exact values are in the figure data below.
Illustrative correction responsibilities

A remediation map links the defect to affected records, financial consequences, communication, and closure evidence. It should retain exclusions and unresolved cases. A change that prevents future failures does not by itself correct earlier customer outcomes.

Figure data and text version
FromToRelationship
Institution-specific duty mapAffected populationReproducible query
Affected populationFinancial reviewAmount and balance impact
Affected populationCustomer messageRequired communication
Financial reviewClosure evidenceVerified adjustment
Customer messageClosure evidenceDelivery and follow-up

Connect the result to the system

Map each applicable duty to the responsible entity, delegated task, evidence, and oversight.

Check the population, evidence, permitted action, and actual effect together. A balanced calculation can still use the wrong population; a successful response can still leave an unknown financial outcome. The case’s numerical result applies only to its stated assumptions.

Sources and further reading

The chapter sources support the concepts and scope. They do not prescribe the synthetic model rates.

  1. FinCEN: Customer Due Diligence Rule and current resources
  2. FATF Recommendations: international standards
  3. FFIEC: BSA/AML Examination Manual