Write the decision as a note that survives examination

A compliance decision has been made and now has to go into the file. The reader who matters is not the customer and not your manager — it is the examiner, auditor, or litigator who opens this note a year later and asks one question: did a real person decide this, for a stated reason, on the basis they said, under a rule that actually applies? The note is the only evidence that the answer is yes.

Left alone the base model writes the wrong document. It produces a persuasive paragraph that argues toward the outcome and hedges every clause: "After reviewing the account activity, it appears the transactions are likely legitimate and probably consistent with the customer's expected behavior. While we cannot be entirely certain, it seems reasonable to clear the alert." That note states no determination you can point to, no specific facts, no rule, no date, no author — and it speculates about what the customer "probably" intended. Every one of those is a finding waiting to happen. Speculation and hedging are not caution; in a record they are the defect.

The discipline is one shape, and every note has all of it:

Determination → basis → rule → attribution, as a record, not an argument.

The determination goes first, stated flat

Open with the disposition as a bare declarative the reader can lift out in one line: Alert cleared. / Exception approved. / Wire declined. / No SAR filed. / Hold released. Not "after careful consideration we have decided that it may be appropriate to" — just the decision. A reader scanning the file must be able to see what was decided without reading to the end. Do not bury the determination under the reasoning that led to it; the reasoning is the basis, and it comes after.

The basis is what was actually reviewed — nothing more

State the specific facts and documents the decision rested on, concretely: the exact amounts, dates, account or reference identifiers, and the named documents examined (e.g. "the three wires of $9,400 on 03/02, 03/04, and 03/07," "the customer's stated occupation on the CIP form," "the 2023 audited financials on file"). Two rules govern the basis:

• Only what was actually reviewed. If a document was not examined, it is not part of the

basis — do not imply a review that did not happen. A note that lists evidence nobody looked at is worse than one that omits it.

• What is unknown is named as unknown. If a fact was not established — source of funds not

confirmed, counterparty not identified — say so plainly ("source of funds not documented") and do not fill the gap with an assumption. A recorded unknown is defensible; an invented certainty is not.

The rule is cited by its identifier, and the facts are tied to it

Name the specific provision, threshold, or policy the determination applies — by its section, number, or defined name ("AML Monitoring Policy §4.2, structuring threshold," "OFAC 50 Percent Rule," "Gifts & Entertainment Policy, $250 pre-approval limit") — and state how the reviewed facts meet or fail it. "Per policy" and "in accordance with our procedures" are not citations; they hide the one thing the examiner is checking, which is whether the rule invoked actually governs these facts. The tie is explicit: this fact, measured against this threshold, produces this result.

The note is contemporaneous and attributable

A record made at the time by an identifiable person carries weight; an undated, unsigned one does not. Every note ends with, or carries, two things:

• A date — when the determination was made (and, where the standard requires it, the period

the review covered). The note reads as written at decision time, not reconstructed later.

• An attribution — the name or role of the decision-maker who made the call. The record is

attributable to a person, not to "the system" or an unnamed "we."

No speculation, no hedging

These two are what separate a record from a draft, and the base model fails both by default.

• No speculation about intent or motive. Record what was observed and what was decided. Do not

guess why the customer did something, whether they "intended" anything, or what "likely" happened out of view. If intent matters to the rule, record only the observable facts that bear on it and let the determination stand on those.

• No hedging prose. Strike appears, seems, likely, probably, presumably, it is believed,

arguably, one could argue, we feel. A determination is recorded as made — with its stated basis and its stated rule — not argued for as if the outcome were still in doubt. Calibrated facts are fine ("two of the five invoices were missing"); hedged conclusions are not ("the invoices probably would have matched").

The shape, in one note

> Determination: Alert cleared; no further action. > Basis: Three incoming wires ($4,200 / $3,900 / $4,600) on 05/11–05/14 to acct 8821, > flagged by the aggregation rule. Reviewed: customer CIP profile (occupation: general > contractor), the originator names on each wire (all the customer's disclosed LLC), and the > prior 12-month transaction history showing similar recurring deposits. Source documents for two > of the three wires on file; the 05/14 wire memo not retained (noted, not material to the below). > Rule applied: AML Monitoring Policy §4.2 (structuring, sub-$10k aggregation). Aggregated > $12,700 over 4 days is consistent with the customer's documented business-deposit pattern and > shows no fragmentation to evade the reporting threshold; §4.2's structuring indicators are not > met. > Decided by: J. Okafor, BSA Analyst — 05/16/2026.

Same four parts, every time. What is not established is named, not filled. Nothing is argued; the decision is recorded.

When this applies

Use it once a disposition exists and has to be written to the file — a cleared or escalated alert, an approved or denied exception, a declined or released transaction, a documented policy-deviation call. Do not use it to make the decision (that is the underlying adjudication), to write the letter that goes to the customer, to draft a SAR narrative for a regulator, or to roll many decisions into a period or board report — those are different documents with different readers.