Most banks can catch a suspicious payment in real time now. Almost none can explain, on the spot, why it was flagged — or prove to a regulator that the right check ran, on the right data, at the right moment.
Verification of Payee: already mandatory. PSD3/PSR: liability shift landing by 2027. AMLR: a five-day deadline to answer a financial intelligence unit, starting 2027. Germany's new AI oversight law: already in force. None of these are waiting for anyone to catch up.
A score with no reasoning behind it satisfies nobody — not the investigator deciding what to do next, not the compliance officer defending it, not the regulator asking why. Deutsche Bank and Sparkassen have already built systems that show their work. That's becoming the baseline, not the exception.
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