DocumentsProcurement and compliance

Where Mirror sits in a financial-crime programme

2 min readSource fincrime-alignment.mdsha256 1d502df7b4a96fea…

A generic map to the usual parts of an AML/CFT programme. A bank maps it onto its own programme; that per-bank mapping is the bank's work. This page says, for each part, what Mirror contributes and what it deliberately does not.

Programme partWhat Mirror contributesWhat it does not do
Enterprise risk assessmentCorridor-level facts: divergence and undetermined rates per corridor, with denominators, released above a k floor (/macro); the geometry certificate stating what each agreed table cannot seeIt produces no risk rating and no score, of a customer, a corridor or a member
Customer due diligence / KYCPerpetual-KYC triggers as commitments, and corroboration when two institutions independently flag one entity; blind related-party checksIt holds no customer identity and makes no CDD decision
Transaction monitoring (trade)A cross-institution three-state verdict per shipment: reconciled (with an independent witness), divergent, or undetermined with its reasonIt is not a monitoring system for anything else, and not a rule engine
Alert investigationThe case chain (custody of a verdict inside the case system), party-to-party disclosure with a signed request and grant, recall notices when a witness fallsIt holds no case content and no investigator notes
Suspicious-activity reportingNothing. A filing decision is refused at the door and in the verifierIt never holds, carries or infers a filing decision (the tipping-off wall)
Record keepingEvery verdict signed and held by the parties; the ten-year verification escrow; offline verificationIt stores no raw record
Governance and oversightQuorum-ratified corridors and witnesses; the change-controlled refusal list; a signed roadmap; the supervisor seatIt holds no committee's decisions beyond ratifications
Model risk / validationDeterministic kernels, the verdict certificate (every configuration checked), the model-validation dossier (/dossier), conformance vectorsIt contains no model to validate: no training, no weights, no score
Independent testingThe synthetic autopsy (planted cases), known-answer canaries, a public filing-term corpusIt is not an independent test of itself. External testing is the bank's or an auditor's.
TrainingPlain-language pages and the consoleNo certification of people. A self-issued credential is on the roadmap's Refused list.

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