Purpose
Register the three supplied Crystal Intelligence calibration documents as a controlled implementation and change record supporting PROC-AML-004 Perform Transaction Monitoring and Alert Review and PROC-KYC-005 Perform Ongoing KYT KYV Monitoring and Periodic Review.
These documents are configuration rationale and change records. They do not replace the operating KYT procedure, case-review instructions, FIU escalation procedure, sanctions decision process, system administration standard or release-approval evidence.
Audience
- Compliance and MLRO personnel responsible for risk appetite, alert review and escalation.
- Technology personnel responsible for Crystal configuration, integration and change execution.
- Operations personnel responsible for complete transaction inputs and correct handling of non-clear outcomes.
- Management and assurance personnel responsible for approval and independent validation.
Document Sequence
| Date | Document | Role in the sequence | BCMS treatment |
|---|---|---|---|
| 2026-07-05 | Crystal Calibration Memo | Initial documented threshold and alert-grade baseline. | Historical design record; later calibration differs materially. |
| 2026-07-07 | Crystal Calibration Memo | Revised design using direct/close amount thresholds and remote percentage thresholds. | Later design record; not proven to be the approved or deployed baseline. |
| 2026-07-13 | Crystal Intelligence Calibration Change Report | Proposed removal of most USD 2,500 close-hop rules and change of 75% risk-score alerts from High to Severe. | Latest proposed delta; approval and deployment are not evidenced. |
The reports must be read chronologically. They must not be combined into a synthetic configuration by selecting thresholds from different dates.
Material Changes
5 July baseline
- Deposit and withdrawal risk score at or above 75% generated a High alert; blocklist interaction was Severe.
- Connection and Risky Amount rules used multiple fixed USD thresholds, distance limits and a mixer percentage rule.
- A 60-day review after operational use was required.
7 July revision
- Direct or one-hop sanctions exposure above USD 100 was Severe.
- Most serious-category exposure within one to three hops used a USD 2,500 threshold.
- Remote Risky Amount thresholds used 3% for sanctions, terrorism financing and enforcement action, and generally 5% for other high-risk categories.
- Deposit and withdrawal risk score at or above 75% remained High.
- A 60-day review after operational use was required.
13 July proposed change
- Retain fixed amount rules only for direct sanctions above USD 100, direct terrorism financing above USD 1,000 and any direct blocklist interaction.
- Remove most USD 2,500 Counterparty Connection rules covering one to three hops.
- Continue percentage-based Risky Amount rules up to six hops using 3% for critical categories and generally 5% for other listed categories.
- Change deposit and withdrawal risk score at or above 75% from High to Severe.
- Review operational results after 30 days.
Current Baseline Decision
The supplied documents do not establish which configuration is currently approved and deployed. The 13 July report repeatedly describes the change as proposed and contains no explicit approval or deployment record. Therefore:
- BCMS does not designate any threshold table in these reports as the authoritative production baseline.
- Technology must retain and compare a dated production export against the approved change record.
- Compliance and the Managing Director must approve the exact active rule set before this publication moves beyond
review. - Operators must use the approved live configuration and operating procedure, not this summary, when handling a case.
Publication Rules
- Format: Three controlled PDF artifacts with one BCMS registration record and chronological interpretation.
- Content cutoff: 2026-07-13.
- Classification: Restricted because the documents disclose financial-crime monitoring thresholds and control logic.
- Retention: Retain every version, approval, configuration export, deployment record, validation result and subsequent calibration for the AML record-retention period.
- Supersession: A later memo does not retire an earlier baseline until approval and deployment are evidenced.
- Use restriction: Do not disclose thresholds to clients or unauthorized third parties.
Approval
- 5 July memo: Prepared by Cees Quirijns; no separate approval statement is shown.
- 7 July memo: Prepared by Cees Quirijns; no separate approval statement is shown.
- 13 July report: Issued for Bitkaya B.V.; no author, reviewer, approver, approval date or deployment date is shown.
- Required business owner: Compliance.
- Required technical owner: Technology, with named administrator confirmation.
- Required approver: Managing Director.
- BCMS status remains
reviewuntil the exact production baseline, approval and deployment evidence are recorded.
Published Artifacts
| Artifact | Pages | SHA-256 |
|---|---|---|
| [[09 Publications/Artifacts/20260705 Crystal Calibration Memo.pdf | 20260705 Crystal Calibration Memo.pdf]] | 7 |
| [[09 Publications/Artifacts/20260707 Crystal Calibration Memo.pdf | 20260707 Crystal Calibration Memo.pdf]] | 11 |
| [[09 Publications/Artifacts/20260713 Crystal Intelligence Calibration Change Report.pdf | 20260713 Crystal Intelligence Calibration Change Report.pdf]] | 6 |
All pages were visually inspected on 2026-07-26. The reports are readable and their tables render without material clipping or overlap.
Required Evidence
- Approved pre-change and post-change Crystal configuration exports.
- Change request, risk assessment, reviewer and approval record.
- Test cases and results for direct, remote, boundary, below-threshold, above-threshold, blocklist, unavailable-service and regression scenarios.
- Deployment date, implementer, verifier and rollback evidence.
- Alert population and disposition data for the required post-change period.
- False-positive analysis, missed-risk analysis, staff workload and selected-case review.
- Evidence that direct sanctions, terrorism-financing and blocklist cases cannot be cleared solely because a percentage threshold is not met.
- Independent confirmation that the live Odoo/Crystal integration uses the approved profile and handles failures and non-clear outcomes correctly.
Relationships
- Crystal system: SYS-KYT-001 Crystal Intelligence Blockchain Analytics
- Primary AML procedure: PROC-AML-004 Perform Transaction Monitoring and Alert Review
- Ongoing KYT procedure: PROC-KYC-005 Perform Ongoing KYT KYV Monitoring and Periodic Review
- Release assurance: PROC-IT-007 Maintain Software Testing and Release Assurance
- Operating KYT SOP: PUB-KYT-001 Odoo Pre-Trade and Post-Trade KYT Controls SOP
- Calibration issue: ISS-KYT-001 Approve and Validate Crystal Intelligence Calibration
History
- 2026-07-26: Registered and compared the 5 July, 7 July and 13 July 2026 Crystal calibration records.