Implementation overview
This brief describes how the recommended event stream plus state snapshot strategy is implemented in practice using Loci's composable infrastructure, and outlines an initial baseline control set suitable for regulatory-grade deployment. It translates the strategy into concrete implementation guidance, while remaining readable to senior technical, risk, and compliance leaders.
The objective is not maximum coverage on day one, but strong baseline controls, explainability and auditability, low operational overhead, and a foundation that can evolve.
Loci evaluates every transaction as the primary decision event. At decision time, the engine draws on four sources of intelligence: three data surfaces you maintain, and one the engine computes for you.
If a metric can be derived from transaction history, you do not build a table for it. All four sources are evaluated at transaction time, producing a single, explainable decision.
The data model: two tables plus your lists
Loci's implementation does not prescribe a rigid schema. Instead, it recommends a minimal, composable data model that supports regulatory-grade controls while keeping operational overhead low.
Every decision in Loci is anchored on a transaction event, enriched by the surfaces below. Each table declares its type and optimization posture; streams that opt into precomputed acceleration commit to being append-only.
entity_events · temporal reasoning and sequencing
| Column | Description |
|---|---|
| account_id | Account / customer identifier |
| event_type | login, password_reset, beneficiary_add, device_registration, etc. |
| event_timestamp | Event time |
| channel | web, mobile, api |
| metadata | Optional structured context (JSONB) |
Keep it high-signal (authentication and profile-change events), not clickstream telemetry.
entity_profile · baseline truth at decision time
| Column | Description |
|---|---|
| entity_id | Account / customer identifier |
| lifecycle_state | new, active, dormant, reactivated |
| last_activity_at | Most recent activity timestamp |
| is_kyc_verified | Boolean |
| risk_tier | Low / Medium / High |
| daily_transfer_limit | Per-entity limit (numeric) |
| country_of_residence | ISO country |
| updated_at | State refresh time |
One wide row per entity; every column reads as a scalar inside a control, for example comparing the transaction amount directly against entity_profile.daily_transfer_limit.
reference_list · institutional knowledge as data
| Table | Columns | Purpose |
|---|---|---|
| high_risk_corridors | country_code, reason, added_at | Corridor screening |
| internal_watchlist | account_number, source, added_at | Counterparty screening |
List edits change detection coverage instantly, with every change on the record.
facts_computed_at freshness timestamp, and let controls gate on recency.
How FLM uses these surfaces
Every FLM control may read events for recent behavior and sequences, read state for eligibility, limits and lifecycle, and read lists for membership and screening, and use live computation for velocity, baselines, deviation and first-time patterns.
All at transaction time, compiled into a single deterministic evaluation. Every score decomposes into named signals; every alert carries the exact logic and values that produced it.
Baseline composable set: the initial 12 controls
The following controls provide broad regulatory coverage while remaining operationally lightweight.
| # | Control | Category | Intelligence |
|---|---|---|---|
| 1 | Dormant-to-Active Reactivation | Lifecycle Risk | State + Live computation |
| 2 | Dormant Account High-Velocity Transfers | Lifecycle + Velocity | State + Live computation |
| 3 | Single Transaction Upper Threshold | Threshold Control | Transaction + State |
| 4 | Weekly Aggregate Value Threshold | Threshold Control | Live computation |
| 5 | Monthly Aggregate Volume Threshold | Threshold Control | Live computation |
| 6 | Rapid Beneficiary Addition + Transfer | Sequencing | Events |
| 7 | Historical Amount Deviation | Behavioral Deviation | Live computation |
| 8 | Structuring via Low Variance Amounts | Layering / Structuring | Live computation |
| 9 | High Velocity Outbound Transfers | Velocity | Live computation |
| 10 | Pass-Through Behavior Detection | Mule / Pass-through | Live computation |
| 11 | New Account Early High-Value Activity | Lifecycle Risk | State + Live computation |
| 12 | Geo or Channel Inconsistency | Contextual Risk | State + Events |
The full baseline requires exactly two custom tables plus your reference lists. Every velocity, deviation, structuring, and pass-through number is computed live by the engine from the history it will defend in an audit.
Control categories
Operational implications
- For compliance teams: clear logic, clear intent, and regulator-friendly explanations, with every alert decomposing into named signals and the values that fired them.
- For engineering teams: two tables and a set of lists to maintain, every rolling metric computed by the engine. Stable data models, predictable access patterns, and low change cost.
- For the business: faster time to coverage, lower operational burden, and confidence at scale.
Most importantly: new controls can be added without refactoring data models, existing controls remain stable as the system evolves, and nothing precomputed means nothing stale, so decisions and their evidence cannot drift apart.
Phased rollout guidance
Phase 1: foundational coverage (day 0-30)
Establish immediate regulatory-grade protection with low operational risk, high explainability, and minimal tuning. These controls are deterministic, easy to explain to regulators, low false-positive risk, and aligned with baseline AML and fraud expectations.
| # | Control | Category | Intelligence | Why phase 1 |
|---|---|---|---|---|
| 1 | Single Transaction Upper Threshold | Threshold Control | Transaction + State | Mandatory baseline control; regulator-expected |
| 2 | Weekly Aggregate Value Limit | Threshold Control | Live computation | Captures volume-based abuse early; nothing to build |
| 3 | Monthly Aggregate Volume Limit | Threshold Control | Live computation | Long-horizon exposure control; nothing to build |
| 4 | Early-Life High-Value Activity | Lifecycle Risk | State + Live computation | Critical for new accounts |
| 5 | Dormant-to-Active Reactivation | Lifecycle Risk | State | Strong signal with low ambiguity |
| 6 | Rapid Beneficiary Add then Transfer | Sequencing | Events | High-risk, easy to justify |
Phase 1 data footprint: the entity_profile state table, the entity_events stream, and your reference lists; every rolling aggregate is computed live. Outcome: strong baseline fraud and AML coverage, immediate regulator confidence, minimal tuning required.
Phase 2: behavioral and network intelligence (day 30-90)
Detect sophisticated, adaptive abuse patterns that emerge after baseline controls are in place. These controls use behavioral baselines the engine builds from accumulated history, and capture patterns missed by simple thresholds.
| # | Control | Category | Intelligence | Why phase 2 |
|---|---|---|---|---|
| 7 | Historical Amount Deviation | Behavioral Deviation | Live computation | Needs baseline history to accumulate |
| 8 | High-Velocity Outbound Transfers | Velocity | Live computation | Benefits from threshold tuning on real traffic |
| 9 | Dormant Account High-Velocity Activity | Lifecycle + Velocity | State + Live computation | Composite behavior pattern |
| 10 | Structuring via Low-Variance Amounts | Layering / Structuring | Live computation | Statistical signal; tune on observed distributions |
| 11 | Pass-Through Behavior Detection | Mule / Pass-Through | Live computation | Requires flow observation |
| 12 | Geo or Channel Inconsistency | Contextual Risk | State + Events | Needs contextual baselines |
Phase 2 outcome: coverage of advanced fraud and AML typologies, reduced blind spots, improved detection of organized or evolving abuse.
Why phased deployment matters
This rollout strategy avoids early false-positive fatigue, allows behavioral history to accumulate naturally (statistical controls activate per entity only once sufficient history exists), gives teams time to build confidence, and aligns with how regulators expect controls to mature.
It also reinforces Loci's core principle: intelligence should grow with the organization.
Closing
This approach does not attempt to predict every fraud pattern. Instead, it provides a clean intelligence foundation, a regulator-aligned reasoning model, and a scalable path forward.
With Loci, fraud and AML controls become structured intelligence, not accumulated complexity.
See it in your stack
A short technical review of your event and state data, then a controlled pilot on the phase 1 controls.