Supervisory AML, fraud and IFF module

What it is

An optional Marengo module that allows a member-state financial supervisor or an EU-level institution to process the AML, CFT, fraud and IFF (illicit financial flow) signals coming from supervised banks in aggregate — not just per institution, but as a market-wide picture.

What "supervisory aggregator level" means

Two structurally distinct layers:

• Bank-internal detection. The bank's own AML, fraud and IFF compliance programme running on its own transaction data. This happens at the bank, on the bank's transaction stream. The Silbad product for this layer is Bucephalus.
• Supervisory aggregator level. The aggregated signals coming from banks — STR statistics, typology distributions, model-performance metrics — synthesised at the supervisory level. This is what the Marengo optional module covers.

The two layers do not compete — the first is the banks' own obligation, the second is the supervisor's mandate. The Marengo module is relevant where the supervisor wants to build the system-wide picture, surface cross-institutional patterns and emit systemic-risk signals on a single analytical surface.

What the module processes

• STR statistics, typology distributions and anomaly signals reported by banks under the regulatory data-reporting framework.
• Macro-level patterns of IFF phenomena across the supervised sector — for example cross-border, coordinated payment movements.
• Aggregated fraud typologies (card, payment, social-engineering) sourced from the regulator's data-reporting flows.
• Effectiveness analysis of typology and risk advisories the supervisor has issued — how much banks catch and at what latency.

How it fits with the rest of Marengo

The module is optional — Marengo's core (SFMA + MAR) does not depend on it. It is worth activating when the supervisor's mandate explicitly extends to oversight of the banking sector's AML/CFT/fraud/IFF system as a whole, and the existing regulatory data-reporting flow is to be turned into an integrated analytical view.

The "we recommend — you decide" principle applies here too: the module produces signals, typology matches and prioritisation. The supervisory decision (open an investigation, communicate with the bank, escalate) stays entirely within the institution.