KONTOGRAPH: Verified Point-in-Time Feature Consistency and Amortised Explanation for Real-Time Anti-Money Laundering under a 200 ms Decision Budget

Regulation (EU) 2024/886 obliges European payment service providers to settle euro credit transfers in under ten seconds, around the clock. This removes both the overnight batch window in which anti-money-laundering (AML) analytics traditionally ran and the settlement delay that made recovery possible, forcing detection, explanation and decision inside a single-digit-second envelope. We present KONTOGRAPH, an end-to-end AML pipeline for the SEPA Instant rail built under a self-imposed 200 ms 99th-percentile budget, and report an empirical study on 1,562,860 simulated payments with injected typologies and deliberately incomplete labels. Three findings are of interest beyond the system itself. First, a temporal graph network with per-node memory improves PR-AUC over a gradient-boosted tabular baseline from 0.0053 to 0.1717, a paired day-blocked bootstrap difference of +0.166 with 95% CI [0.105, 0.241]; per-node memory alone more than doubles the score. Second, expressing each feature once and compiling it to three execution backends, with equivalence enforced by property-based tests that perturb the future, surfaced three point-in-time violations that code review had passed--each of which would have inflated reported performance. Third, and most consequential for practice, exporting the deployed tree ensemble to ONNX changed only $7.4 \times 10^{-8}$ in mean score yet altered 0.26% of decisions and inflated the alert volume by 12%, because 32-bit accumulation perturbs scores across a cost-optimal threshold of $3.98 \times 10^{-4}$. We argue that a serving-format conversion must be treated as a model change until measured, and that fidelity metrics for subgraph explainers can be vacuous when candidate neighbourhoods are small--a null result we report in full.

SALT-GNN: Handling Dense Neighborhoods in Anti-Money Laundering Graphs via Statistics-Aware Attention

Money laundering threatens financial stability and exposes institutions to penalties, motivating automated detection. Because laundering schemes often emerge through relational patterns, graph neural networks (GNNs) are increasingly used for anti-money laundering (AML). Yet AML GNNs are typically evaluated with aggregate metrics such as overall F1 score, which hide an operational issue: high-activity recipient accounts concentrate many incoming transactions, making suspicious signals harder to isolate and costlier to investigate. We introduce a recipient-degree stratified evaluation that reports standard AML metrics across recipient-context density. Across three datasets (HI-Small, HI-Medium, and AMLSim-32k-5%), it reveals consistent degradation in dense recipient contexts, which we trace to three GNN characteristics: two known limitations that AML amplifies, i.e., (1) multiset non-discriminability and (2) cardinality blindness, and (3) an attention-specific effect: in dense neighborhoods, normalized attention attenuates weak but pattern-relevant multi-hop signals. Guided by this diagnosis, we propose SALT-GNN, a lightweight statistics-aware architecture that fuses degree-aware statistical aggregation with attention at each message-passing layer, so distributional and cardinality information shapes the node states used by subsequent attention steps. Ablations support fusion placement as a key factor in dense-context performance. On HI-Small and HI-Medium, SALT-GNN uses up to 77% fewer parameters than task-specific graph-transformer baselines while improving dense-context F1 score by 3-6 points; on AMLSim-32k-5%, it improves highest-degree F1 score by 16-20 points. The gains hold for both Transformer- and GAT-style attention, indicating that the benefit comes from where statistical and attentional evidence is fused rather than from a specific attention operator.

Counterfactual Methods for Detecting Unfairness in Anti-Money Laundering Algorithms

The application of machine learning-based predictive algorithms to Anti-Money Laundering (AML) has grown rapidly, driven by the vast volume of financial transaction data available to banks. These algorithms are typically trained not only on transactional data but also on sensitive client information, which may raise fairness concerns. Despite this, AML detection systems remain largely underexplored from a fairness perspective, even though deeper analytical methods based on counterfactuals are now available. Such techniques enable the decomposition of the direct and indirect effects of potentially sensitive features on model predictions, thereby supporting the evaluation of whether their influence is acceptable from a fairness perspective. Closing this gap, we consider the synthetic IBM AMLSim transaction dataset and construct additional features of the country of an account and its average behaviour. This improves the predictive performance of diverse machine learning models, ranging from baseline decision trees to state-of-the-art graph neural networks. We assess the potential unfairness associated with these features through a counterfactual, path-specific effect analysis. This reveals that fairness violations tend to be more pronounced for models whose predictive performance benefits the most from the extended features. Such a finding highlights a concrete instance of the trade-off between predictive accuracy and fairness in AML applications, thus underscoring the urgency of a systematic fairness analysis in such critical domains.