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SARB Directive 3 · FIC In development

Ledger

Sovereign AML and transaction-monitoring copilot

Ledger is a sovereign copilot for financial-crime teams. It reads flagged transactions and customer history, drafts the suspicious-transaction narrative an analyst would otherwise write by hand, and shows its reasoning, all on infrastructure the bank controls.

A South African financial-crime team reviewing transaction-monitoring dashboards in a Johannesburg bank office at dusk
[ DEMO ]

See Ledger draft an STR narrative

A flagged transaction, worked the way Ledger would: signals weighed, customer risk assessed, and a suspicious-transaction narrative drafted for an analyst to file. Runs on the bank's own infrastructure. An illustration of the workflow, not live customer data.

Flagged transaction ALERT TM-77310
  • CustomerAcct ****4471 · onboarded 11 days ago
  • Activity3 cash deposits, R49,500 each, same branch, 4 days
  • Thenfull EFT to a new third party within 24h
  • Profilestated income R18,000/month
Stays in SA
  1. Signals analysed3 structuring and layering indicators identified
  2. Customer risk assessedDeposits sit far above stated income · new account
  3. Typology matchedPattern consistent with structuring then layering
  4. Narrative draftedReady for an analyst to review and file
Analyst-in-the-loop. Ledger never files autonomously.
[ WHY ]

Why it exists

Transaction and KYC data is triple-bound: POPIA, the FIC Act, and SARB Directive 3 on cloud computing and offshoring. An offshore LLM endpoint touches all three. Ledger is designed so the model runs inside the bank or on sovereign cloud, with an explainability layer that lets a SARB or FIC reviewer see exactly why a narrative was drafted the way it was.

[ HOW ]

How it works

01

Ingest

Flagged transactions and linked KYC records are pulled into a sovereign workspace. No data egress.

02

Reason

The model assembles the risk picture and proposes a narrative, citing the specific signals it used.

03

Review

An analyst edits and approves. The copilot never files anything autonomously.

04

Evidence

The reasoning trail is preserved so the decision is defensible to FIC and SARB.

Regulatory frame

  • § SARB Directive 3 (cloud and offshoring)
  • § FIC Act (STR/SAR obligations)
  • § POPIA (transaction and KYC personal data)

Wrestling with this now?

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