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

arXiv: https://arxiv.org/abs/2608.22389 · HTML: https://mlsanity.com/paper/2608.22389/

## Key facts

- No citing papers in the map yet (data through 14 Oct 2026).
- Builds on 10 of its 21 references that are in the map.
- First posted on arXiv 23 Aug 2026.

## Builds on (most cited first, 10 of 10)

- [A Unified Approach to Interpreting Model Predictions](https://mlsanity.com/paper/1705.07874/) (2017)
- [Counterfactual Explanations without Opening the Black Box: Automated Decisions and the GDPR](https://mlsanity.com/paper/1711.00399/) (2017)
- [ERASER: A Benchmark to Evaluate Rationalized NLP Models](https://mlsanity.com/paper/1911.03429/) (2019)
- [Temporal Graph Networks for Deep Learning on Dynamic Graphs](https://mlsanity.com/paper/2006.10637/) (2020)
- [Inductive Representation Learning on Temporal Graphs](https://mlsanity.com/paper/2002.07962/) (2020)
- [Predicting Dynamic Embedding Trajectory in Temporal Interaction Networks](https://mlsanity.com/paper/1908.01207/) (2019)
- [Parameterized Explainer for Graph Neural Network](https://mlsanity.com/paper/2011.04573/) (2020)
- [On Explainability of Graph Neural Networks via Subgraph Explorations](https://mlsanity.com/paper/2102.05152/) (2021)
- [Anti-Money Laundering in Bitcoin: Experimenting with Graph Convolutional Networks for Financial Forensics](https://mlsanity.com/paper/1908.02591/) (2019)
- [Realistic Synthetic Financial Transactions for Anti-Money Laundering Models](https://mlsanity.com/paper/2306.16424/) (2023)

## Abstract (arXiv)

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 × 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 × 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.